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2022 (3) TMI 529 - AT - Income TaxDisallowance of claim of depreciation, interest expenditure and administrative expenditure in respect of Block-C - claim disallowed by the AO on the ground that the asset was not “put to use” - HELD THAT:- We find that in assessment year 2013-14 the Assessing Officer had accepted the contention of assessee that Block-C is complete and allowed assessee’s claim of depreciation, administrative and interest expenditure qua Block-C. In respect of the remaining project the administrative and interest expenditure was allowed to be capitalized. The CIT(A) in the impugned assessment year allowed assessee’s claim in respect of depreciation, interest and administrative expenditure pertaining to Block-C on the ground that Department has accepted in assessment year 2013-14 that Block-C has been “put to use”. Once having accepted this position, the AO cannot change his opinion in immediate next assessment year without there being any change in facts and circumstances. We find no infirmity in the impugned order, hence, the same is upheld. - Decided against revenue.
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