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2022 (5) TMI 158 - ITAT DELHIDisallowing expenses on account of additional depreciation - appellant has claimed additional depreciation on new plant & machinery purchased and installed during the year as per the provisions of section 32(iia) - HELD THAT:- As relying on SCIENTIFIC ENGINEERING HOUSE PVT. LIMITED VERSUS COMMISSIONER OF INCOME-TAX, AP [1985 (11) TMI 1 - SUPREME COURT] since tools, dies, jigs etc. are used by the appellant for its business of manufacturing switchgear products it is evident that moulds, dies and tools are not independent of the plant and machinery, but are parts of the machinery. Once they are worn out, the machines cannot turn out the product to the business specifications and this has to be obtained only on a replacement of the tools or the dies and moulds. Further also, in assessee’s own case in the subsequent years, the revenue has allowed the claim of additional depreciation on these tools etc. and thus the ground raised in the appeal is allowed.
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