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2018 (5) TMI 626 - AT - Income TaxAdditional depreciation u/s. 32(1)(iia) on items installed in the various outlets - proof of manufacturing activities - Held that:- As obvious from the financial statement that about 91% of the Revenue is collected by the assessee from manufacturing activities and 9% thereof is earned from restaurant. Also, the equipments or plants are installed at those premises. AO has not brought any material on record to show that those plants are installed at any office premises or any residential accommodation in the nature of guest house. It is also a matter of common knowledge that Air Conditioners are required at manufacturing outlets to keep the sweets also in proper condition over and above refrigerators. Electricity distribution penal also cannot be said to be installed at residential place. No material is brought on record by the AO that the outlets do not manufacture sweets. It is of paramount importance that the AO has granted normal depreciation on all those items holding them to be plant and machinery. Assessee has satisfied the conditions for additional depreciation. No justification to interfere with the order of the CIT(A) for allowing additional depreciation, as claimed by the assessee. - Decided in favour of assessee.
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