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2019 (2) TMI 1142 - HC - Income TaxClaim of depreciation at 100% in the very same year in which the purchase was made - capitalisating the expenses incurred on purchase of tools, can the assessee - assessee admits that it had capitalised the amounts spent on small value tools in the very same year however, noticing the discrepancy reversed it and written off the entire value in the very same year in which they were rendered useless after use in the manufacturing process. The claim in the return was as a revenue expenditure - HELD THAT:- The write off was on account of the tools being rendered useless after use in the manufacturing process. This necessitates frequent purchase of the said tools for continuous manufacturing process. In the nature of the industry, the same is allowable as a revenue expenditure. The adjustment made by the assessee was wrongly understood by the AO at the first instance. If it had been properly understood, then, the entire amounts would have been allowed as a revenue expenditure. In such circumstances, we do not think that there is any cause for interference with the order of the Tribunal. The question framed does not at all arise as one on law. The Income Tax Appeal is, hence, rejected.
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