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TMI Blog1987 (1) TMI 158X X X X Extracts X X X X X X X X Extracts X X X X ..... etion of Rs. 4,97,548 in respect of the value of over-head tanks belonging to the assessee. The WTO found that the assessee was proprietor of M/s Pradeep Oil Corporation. There were some over-head tanks which had to be valued as on the valuation date which was31st March, 1979. The WTO found that the assessee had claimed depreciation at 30 per cent on the over-head tanks and thus the written down v ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n allowed at a higher rate and it was on this basis that the WTO adopted a higher value in anticipation of the assessment to be made. 3. Before the AAC, it was submitted that as the reassessment proceedings had not been finalised, the value should have been taken on the basis of the assessment already made. A reference was also made to the Rules under the WT Rules. The AAC was of the view that th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of assets shall be taken in the case of depreciable assets on it written down value. The meaning of the term "written down value" has to be the same as under the IT Act. The WTO was not contemplating to adopt r. 2B(2) but only 2B(1) by taking the value at the written down value and he was proceeding on the basis that the claim of the assessee was based on a wrong calculation of the written down v ..... X X X X Extracts X X X X X X X X Extracts X X X X
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