TMI Blog2019 (2) TMI 1142X X X X Extracts X X X X X X X X Extracts X X X X ..... 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... K. JOHN MATHAI AND SRI. P. BENNY THOMAS JUDGMENT Vinod Chandran, J . The question raised is as to whether after capitalisating the expenses incurred on purchase of tools, can the assessee claim depreciation at 100% in the very same year in which the purchase was made? 2. The Assessing Officer is said to have allowed it, which was sought to be rectified under Sectio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... year. However, noticing the discrepancy, the assessee had 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. 4. The learned counsel also relies on (1990) 182 ITR 493 [Commissioner of Agricultural Income Tax v. Midland Rubber and Produce Co. Ltd.] ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 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. No order as to costs. - - Tax ..... X X X X Extracts X X X X X X X X Extracts X X X X
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