TMI Blog2022 (1) TMI 1273X X X X Extracts X X X X X X X X Extracts X X X X ..... on constructing and maintenance of road facility was actually incurred towards Acquiring right to collect toll which formed an `Intangible asset eligible for depreciation u/s.32(1)(ii) - CIT(A) deleted the disallowance - HELD THAT:- Vide order . [ 2017 (11) TMI 1998 - ITAT PUNE] dealt with such issue and held the assessee to be eligible for depreciation on the Right to collect toll , being, a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Revenue are directed against the consolidated order dated 13-06-2018 passed by the CIT(A)-12, Pune in relation to the assessment years 2012-13 to 2014-15. Since a common issue is raised in these appeals, we are, therefore, proceeding to dispose them off by this consolidated order for the sake of convenience. A.Y. 2012-13 : 2. The only issue raised in the appeal is against the deletion ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted, the assessee submitted that the expenditure incurred by it on constructing and maintenance of road facility was actually incurred towards Acquiring right to collect toll which formed an `Intangible asset eligible for depreciation u/s.32(1)(ii) of Act. Not convinced, the AO made disallowance of depreciation of Rs.151.84 crore which got allowed in the first appeal. Aggrieved thereby, the Rev ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... /PUN/2016 dealt with such issue and held the assessee to be eligible for depreciation on the Right to collect toll , being, an intangible asset. The Tribunal, in turn, followed another order of the Coordinate Bench in Ashoka Highways (Bhandara) [ITA No.1299/PUN/2015] which held that the cost of constructing road was akin to Right to collect toll , being, an intangible asset. The ld. DR fairly ad ..... X X X X Extracts X X X X X X X X Extracts X X X X
|