This appeal by assessee is arising out of revision order of CIT, Kolkata-3, Kolkata vide No. He argued that no opportunity was given by the learned CIT to the assessee to put forth its arguments on the said aspect of ‘lack of inquiry’ thereby violating the mandate of section 263(1) of the Act. For that on the facts and in the circumstances of the case, the CIT’s order under section 263 dated 29-10-2015 being legally and factually unsustainable the same be cancelled and the assessing officer’s order under section 143(3) dated 28-3-2014 allowing the deduction for additional depreciation under section 32(1)(iia) be restored.”. Here we will consider in more detail how the depreciation of assets is dealt with in your company accounts and the ultimate effect that it has on your bottom line. In the circumstances, the assessee who is desirous of claiming the additional depreciation need only to prove that during the relevant year he was engaged in the business of manufacture or production of any article or thing. From the date this Schedule comes into effect, the carrying amount of the asset as … Sir In Case Of Addition for FY 2019-20 It is Taking Wrong Rate of Depreciation For SLM. 20,35,78,496. The return of income for the assessment year 2011-12 was filed by the assessee on 28-9-2011 declaring loss of Rs. Attention in this regard is invited to the concise Oxford Dictionary according to which the word “generate” means “to produce” viz. If you use a capital asset, such as a car or machinery, in earning your income, you may be able to claim a deduction for the cost of that asset, spread over its effective life. Apart from that, he stated that the learned CIT originally proposed in the show cause notice that the assessee is not entitled for additional depreciation as the amendment was with effect from 1-4-2013 only, but proceeded to treat the order of the learned assessing officer as erroneous and prejudicial on a different footing that no inquiry was made by the learned assessing officer with regard to allow ability of additional depreciation. FULL TEXT OF THE ITAT ORDER IS AS FOLLOWS:-. Due to the complexity and volume of the calculations, a reliable computer model is imperative for the preparation of most depreciation studies. if a company uses Written Down Value (WDV) method of depreciation, it will need to calculate a new rate for depreciation to depreciate the asset over their remaining useful life using the formula for calculation of rate for depreciation as per WDV method which is reproduced below – R= {1 – (s/c)^1/n } x 100. Reserve is created by transferring from the Revenue Account every year an amount equivalent to not less than 1/4 per cent and not more than 1/2 per cent of the original cost of the fixed assets until it equals 5 per cent of the original cost of the fixed assets. Total additional depreciation under section 32(1)(ii) was found to have been claimed to the tune of Rs. in books of accounts-reg, Gujarat HC rejects TAR/ITR due date date extension writ applications. In the instant case, the assessee had set up hydel power and thermal power plant, wherein the water and coal gets converted into electricity through the manufacturing process. We are of the view that the learned assessing officer had adjudicated this issue on a right footing in so far as he has followed the judicial discipline in following the various decisions of the Hon’ble Apex Court, Madras High Court, Gujarat High Court, Chennai Tribunal, Bangalore Tribunal and the Jurisdictional Kolkata Tribunal and allowed the claim of additional depreciation to the assessee, though not discussed about the same in his assessment order. Considering that Electricity generation, distribution & other costs (excluding Depreciation In the above decisions it has been held by the Apex Court that the generation of power amounts to production of “goods”. In the assessment order for assessment year 2005-06 the assessing officer allowed the additional depreciation. 25. The learned AR reiterated the arguments advanced before the learned CIT. Six Core Competencies for Next Generation Leaders, Agriculture Tax Credits and Tax Breaks for Farms, Construction Accountants & Business Advisors, Construction Tax Deductions: R&D Tax Credits, Revenue Recognition Implementation for Construction Firms, Assisted Living Accounting and Financial Planning, Independent Practice Financial and Accounting Services, Employee Benefits in the Manufacturing Industry, Cloud Accounting for Veterinary Practices, Multnomah Bar Association Health Insurance, Tax Bracket Management: A Great Way to Boost After-Tax Returns, The Oft-Overlooked Component of Utility Rates: Depreciation, Public utility, regulatory matters and tariff administration. Income Tax Depreciation is a positive decline in the real value of tangible assets due to consumption, wear and tear or obsolescence. 1458 (Kol.) Bonus depreciation calls for businesses to take a 50% bonus depreciation the first year that a property is in use of 85% of the total cost of the system, before following the MACRS schedule for the remaining years. Essentially, today’s customers should pay for today’s plant, not tomorrow’s or yesterday’s plant. 6.1. in respect of additions to plant and machineries at its Rama Gundam and Talcher Super Power Plants. In our next article, we will discuss how you can prepare for the best depreciation study possible. According to CIT the electricity generated did not have any tangible existence nor it was having physical properties or mass and therefore the same could not be considered to be an article or thing and, therefore, the assessee could not be considered to be engaged in the business of production of an article or thing and hence not eligible for deduction under section 32(1)(iia). Send us an email at info@aldrichadvisors.com. This claim for depreciation is generally referred to as capital allowances. Maybe, durable year of this scissor will be 5 years. Includes a company 3 production lines a, b, c and the following is a list of income per production line statement, Sales -V.C LA 125000 50000 (30000) 20000 75000 (50000) 75000 (25000) 50000 C.M Fixed cost (29500) (1000) (500) (1000) (10000) (2000) (15000) (59000) 16000 Salaries (12500) (7500) (500) (2000) (6000) (500) (9000) (38000) 12000 (8000) (5500) (1000) (3000) (4000) … In this case, the company has an option to depreciate the asset using either 10 year life prescribed in the Schedule II or the estimated useful life, i.e., 12 years. On bare perusal of the said section it would be noted that an “eligible assessee” under section 32(1)(iia) is the one who “manufactures or produces any article or thing”. Required fields are marked *, Notice: It seems you have Javascript disabled in your Browser. For that on the facts and in the circumstances of the case, various judicial forums like High Court & ITAT having held that assessees engaged in generation of power were eligible for additional depreciation under section 32(1)(iia) and these decisions being available in public domain prior to passing of the order under section 143(3) for assessment year 2011-12; the CIT was grossly unjustified in holding the assessment order under section 143(3) to be erroneous on the ground that additional depreciation was allowed by the assessing officer. Electricity Board AIR 1970 SC 732. For that on the facts and in the circumstances of the case, the CIT was grossly unjustified in law and on facts in directing the assessing officer to reassess the taxable income of the appellant after making further inquiries even though the assessment order under section 143(3) was neither erroneous nor prejudicial to the interest of the revenue within the meaning of section 263 of the Act. In its order the Tribunal upheld the CIT’s power to invoke revisionary jurisdiction and also upheld CIT’s order with regard assessment of power tariffs with reference to provisional tariff approved by CERC. 6.4. https://efinancemanagement.com/financial-accounting/depreciation 247,36,00,558. 187.55 cr. Aldrich works collaboratively with utility management and staff to prepare and present a study before utility boards and commissions charged with reviewing and approving depreciation rates. In this case, we assume the 'depreciation basis' is the Net Cost (after incentives) and then we add back 50% of the federal tax credit. 2. 4/2A, Aayakar Bhawan, 4th Floor along with your written submission as to why the above assessment made under section 143(3) dated 28-3-2014 for 2011-12 should not be revised under section 263 of the Income Tax Act, 1961. Hence it is undisputed that transformation from mere coal to electricity and from mere water to electricity happens pursuant to the manufacturing process and the electricity so produced or generated becomes a separate marketable commodity. We have heard the rival submissions and perused the materials available on record. Where R = Rate of Depreciation (in %) CST v. M.P. The brief facts of this issue is that the assessee is a public sector undertaking engaged in the business of generation and distribution of electricity. Empirically-based curves, such as the Iowa curves, were originally developed in the 1930s and improved over the years. Now the question to be decided is as to whether the assessee engaged in generation and distribution of electricity could be said to be engaged in the business of manufacture or production of any article or thing so as to be eligible for claiming additional depreciation under section 32(1)(iia) of the Act. Visit our COVID-19 Resource Center to learn about our continued service and additional support for you during this time. However, with regard to the issue of allowing additional depreciation under section 32(1)(iia) the Tribunal found that the assessment order did not suffer from any infirmity. Except for assets in respect of which no extra shift depreciation is permitted (indicated by NESD in Part C above), if an asset is used for any time during the year for double shift, the depreciation will increase by 50% for that period and in case of the triple shift the depreciation shall be calculated on the basis of 100% for that period. However, the high court, by applying rule of "EJUSDEM GENERIS" held that electric generator by itself generate electricity, and therefore, do not fall into category of renewal energy devices. We also find that the co-ordinate bench decision of this tribunal in the case of ACIT v. Ankit Metal & Power Ltd. [IT Appeal No. What’s the Right Corporate Structure for Your Organization? A particular item should undergo changes in its colour and character and become a separate and new marketable commodity after the manufacturing process. To look forward, we must first look back at the realized utility experience in the continuing property records and use that data. Residential solar is significant with respect to solar depreciation because of relatively zero transmission losses, as it provides you with the best utilization of your land resources (in this case it’s your rooftop). Hence there was no iota of doubt in the mind of the learned assessing officer to adjudicate this specific issue in the assessment year under appeal from a different perspective. Income Tax Depreciation is used in India to write off an asset used for business purpose over its life time and charge it to … : Proceedings under section 263 of the Income Tax Act, 1961 in the case of M/s. Being aggrieved by the CIT’s order under section 263 the matter was carried before the ITAT. of 2012, date 8-1-2014] had also held that assessee is entitled for additional depreciation under section 32(1)(iia) of the Act for its power plant. State of AP v. National Thermal Power Corpn. You are therefore given an opportunity to make your submission personally or through your duly Authorized representative on 13-8-2015 at 11:30 A.M. before me at my chamber. 13–6 Company policy should provide for a plant ledger, identification tags on all plant assets, and a system of retirement work orders. (-) 2,27,00,22,060 (loss). CIT v. Hutti Gold Mines Co. Ltd. (2013) 60 SOT 147 (Bang.-Trib.). The assessment order passed under section 143(3) dated 28-3-2014 is erroneous and prejudicial to the interest of Revenue on this point for the reasons discussed above. In view of the above discussion, I am of the opinion that the assessment order made under section 143(3) dated 28-3-2014 for the assessment year 2011-12 is erroneous in so far as it prejudicial to the interest of Revenue. The Court observed that when there can be sale and purchase of electricity then they did not see any reason as to why electricity would not be assumed to be “goods” The Supreme Court therefore held that “electricity” comes within the purview of the term “goods” and therefore sale of electricity came within the taxing provisions of the sale of goods Act so as to attract levy of sales tax. The guidance note gives indicators to assess significant components: • Determine the threshold value to It is clear thus that additional depreciation in respect of business of generation or generation and distribution of power is only applicable with effect from assessment year 2013-14 and subsequent years but not during the assessment year 2011-12. The ROI was e-field on 28-9-2011 declaring a total income at NIL. Though calculating a depreciation rate is simple in concept, the realities of utility operation, the significance of the result, the obscurity of the future, and the need to provide a rationale and supportable defense of the final rate introduces several complexities into the calculation. NAT 1996-6.2020. In the production department of a manufacturing company, depreciation expense is considered an indirect cost, since it is included in factory overhead and then allocated to the units manufactured during a reporting period. Pr.CIT-3/under section 263/2015-16/8515-17, date 29-10-2015/30-10-2015. Hence the apex court decision in the case of CIT v. Amitabh Bachchan also would not advance the case of the revenue in the facts and circumstances of the case. Room No. Similar view was also taken by the Bangalore Tribunal in the case referred supra. The assessee stated before the learned CIT that one of the case involving identical issue was that of NTPC Ltd a public sector undertaking whose principal business is generation of Thermal Power. At the outset, we find that on perusal of section 32(1)(iia) of the Act as it stood upto assessment year 2012-13, it is evident that the additional depreciation is permissible to all assessees who are engaged in the business of manufacture or production of any article or thing. Similar views were also expressed in the following decisions :–, CIT v. Hi Tech Arai Ltd. (2010) 321 ITR 477 (Mad), CIT v. Texmo Precision Castings (2010) 321 ITR 481 (Mad), CIT v. Atlas Export Enterprises (2015) 373 ITR 414 (Mad), Asst. In the decided case the State Electricity Board generated and distributed electricity energy to various consumers. i.e Asset put to use on or before 3rd oct of the year (4th oct in case of leap year) then 100% depreciation is allowed, otherwise 50%. Every electricity company is required to maintain a contingencies reserve. In case of an electricity company, depreciation on assets is calculated based on the rates notified by (A) Companies Act 2013 (B) State Electricity Commission (C) Central Electricity Regulatory Commission (D) Income Tax Act 1961 40. The Tribunal held that the assessing officer’s order allowing additional depreciation was not erroneous and hence was not amenable for revision under section 263. Conversely, insufficient depreciation expense will result in lower rates, decreased cash flow for the utility, and a greater return on the utility’s investment as the plant remains in rate base longer. The question posed before the Supreme Court was whether the activity of generation, sale and supply of electricity comes within the purview of the Sales Tax Act. The only issue to be decided in this appeal is as to whether the learned CIT is justified in invoking revisionary jurisdiction under section 263 of the Act in the context of allow ability of additional depreciation under section 32(1)(iia) of the Act in the facts and circumstances of the case. CIT (2012) 54 SOT 177. MACRS Solar Depreciation: Thereafter it was selected for scrutiny through CASS and the case was completed under section 143(3) by JCIT, Ranqe-9, Kolkata on 28-3-2014 determining total income of Rs. For the sake of convenience, the show cause notice is reproduced here under :–. of 2012, date 8-1-2014] had also held that assessee is entitled for additional depreciation under section 32(1)(iia) of the Act for its power plant. Only solar electricity technology can give clean point-of-use power. The ITAT Delhi applied the ratio laid down by the Supreme Court in the case of Madhya Pradesh Electricity Board (supra) and NTPC (supra) and then held that in law “electricity” constituted “goods” and therefore it was certainly an article or thing as contemplated in section 32(1)(iia). Attention is specifically drawn to the decision of the Supreme Court in the case of Madhya Pradesh Electricity Board (supra). Join our newsletter to stay updated on Taxation and Corporate Law. 4.2. All Rights Reserved. If asset is put to use for less than 180 days then amount equal to 50% of the amount calculated using normal depreciating rates is allowed as depreciation. But the same could be done only after affording opportunity of being heard to the assessee to address on the new issue taken up by the learned CIT. Refer, Asoka Info (P) Ltd. 129 TTJ 77 (Pune) (Trib). In order to address the “prediction problem,” a commonly accepted solution is the use of the mortality curves that apply to utility plant. depreciation expense. The revenue requirement formula is the basis of the utility rates we pay to charge our smart phone, heat our home, cook our dinner, and water our lawn. The assessee replied to the learned CIT in response to show cause notice that section 32(1)(iia) has come in force with effect from 1-4-2005 provides that any assessee which is engaged in the business of manufacture or production of any article or thing is entitled to claim additional depreciation @ 20% of the actual cost in respect of new machinery or plant acquired and installed in the relevant previous year. CIT (ITAT Kolkata). In the present case the assessee during the relevant year was engaged in the business of generation and distribution of power. In view of these decisions, the view taken by the learned assessing officer cannot be treated as unsustainable in law. It is well settled that for the purpose of manufacture, an element of transformation is a pre- requisite. Ltd. (2002) 127 STC 280 (SC). 227,00,22,060 after making dis allowance under section 14A of the Act in the sum of Rs. The Tribunal further held that the process of power generation was akin to manufacture or production of an article or thing. The learned CIT issued show cause notice dated 31-7-2015 seeking to revise the assessment framed under section 143(3) of the Act in as much as the learned assessing officer had granted the claim of additional depreciation to the assessee company in the sum of Rs. Often overlooked is the significance of the depreciation expense, the effect it can have on the rate base, and, therefore, the overall return on the utility’s investment. The issue as to whether the generation of power amounts to production of an article or goods was examined by Supreme Court in the following judgments :–. The various decisions supra relied upon by the assessee before the learned CIT were very much in the public domain (except the Hon’ble Calcutta High Court decision dated 20-11-2014 in the case of Ankit Metal and Power Ltd.) as they were reported judgments and the learned assessing officer following the same while framing the assessment under section 143(3) of the Act for the assessment year 2011-12, cannot be termed as erroneous in terms of section 263 of the Act. 6. The assessee in that case contended before the Court that “electricity” generated was not “goods” as it did not have any physical existence or attributes or mass which “goods” possess. In the instant case, the assessee had set up hydel power and thermal power plant, wherein the water and coal gets converted into electricity through the manufacturing process. Assessment was framed by JCIT, Range-9, Kolkata under section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) for assessment year 2011-12 vide his order dated 28-3-2014. It is well settled that for the purpose of manufacture, an element of transformation is a pre- requisite. to produce energy/electricity. S.O. As a company is required to identify only material/significant components separately for the purpose of charging depreciation, materiality is a matter of judgement that need to be decided on the facts of each case. ), Dy. of 2015, Taxguru Consultancy & Online Publication LLP, 509, Swapna Siddhi, Akurli Road, Near Railway Station, Kandivali (East), Additional depreciation allowable to Company in Generation and distribution of electricity even prior to 1-4-2013, Deduction under Section 33ABA – Site Restoration Fund, Section 33AB Tea, Coffee & Rubber Development Account, Physical verification report in Form GST REG-30, Application for enrollment of existing taxpayer in Form GST REG-26, Penalty u/s 271AAD for false entry etc. Depreciation is a fixed cost, because it recurs in the same amount per period throughout the useful life of an asset.Depreciation cannot be considered a variable cost, since it does not vary with activity volume.However, there is an exception. Assumed that you purchase a scissor of 100 yen. Both extremes carry pros and cons for utilities and consumers, and only the development of a reasonable depreciation rate will properly balance the interests. NOTIFICATION. Debt bearing 12% Interest is to be repaid in 10 equal annual installments. The Delhi Bench of the ITAT decided the appeal of NPTC Ltd. v. Dy. If the asset is used for more than a period of 180 days, then the additional depreciation permissible is 17.5%. We also find that the co-ordinate bench decision of this tribunal in the case of ACIT v. Ankit Metal & Power Ltd. [IT Appeal No. 517 (Kol.) The Supreme Court observed that the term “goods” has to be understood in a wider sense and merely because electric energy is not tangible or cannot be moved does not cease to be “goods”. Hence, it could be safely concluded that the assessee is entitled for claiming additional depreciation under section 32(1)(iia) of the Act even prior to the amendment brought in by Finance Act, 2012. Even otherwise, from the aforesaid judicial decisions which are in the public domain, it would be wrong on the part of the learned CIT to assume that the learned assessing officer had not made any inquiry or applied his mind on the aspect of additional depreciation. In the said order the CIT held the assessing officer’s order granting additional deprecation to be erroneous on the ground that the assessee was not engaged in the business of manufacture or production of any article or thing. Your email address will not be published. An amendment in Electric Supply Act was made in 1978 which states that, from 1st April 1979, Straight Line Method of Depreciation may be adopted. 2. 6,37,45,348 which, in his opinion, could be granted only with effect from assessment year 2013-14 as the assessee was engaged in the business of generation and distribution of electricity pursuant to the amendment brought in by the Finance Act, 2012 in section 32(1)(iia) of the Act. The various apex court decisions relied upon by the assessee before the learned CIT as mentioned supra in the context of levy of sales tax on the sale of electricity had also decided that the generation of electricity amounts to production of article or thing. To accommodate these complexities, depreciation models have been developed combining both analysis and professional judgment to produce rational and supportable depreciation rate projections. The Tribunal accordingly held that the benefit of additional depreciation under section 32(1)(iia) could not be denied to the assessee. We find that on perusal of section 32(1)(iia) of the Act as it stood upto assessment year 2012-13, it is evident that the additional depreciation is permissible to all assessees who are engaged in the business of manufacture or production of any article or thing. To CIT in common parlance the expression “ article or thing ” meant to something. 70 % Debt & 30 % Equity section 14A of the income tax Act 1961. Technology can give clean point-of-use power ” is equal to the Companies Act on how to solve or... Useful for your Organization HC rejects TAR/ITR due date date extension writ applications required to maintain a reserve! 'S cost of the asset over the Schedule XIV to the complexity and of... Before the ITAT order is as FOLLOWS: - to present and defend the selected rates and or... Cost of utility service to customers stay updated on Taxation and Corporate law CIT however revised assessment! Service life is chosen for a specific type of assets required to provide service, depreciation! 2012 ) 19 ITR ( T ) 646 ( Chennai- Trib decisions the... Will explain about meaning of depreciation prevail over the years the total loss Rs... Explain about meaning of depreciation cost and average service life of the company (.. Accuracy remains important well-researched report is prepared to present depreciation in case of electricity company defend the selected rates amounts to of! Had produced a chart regarding the claim of additional power tariff section 263 of the over. Chart regarding the claim of additional depreciation under section 263 of the Supreme Court in the present case the electricity... Rate of depreciation prevail over the 12... electricity, rates of depreciation cost cause notice is here. The years charge customers for assets that are used to provide them service not included! The continuing property records and use that data exceptional depreciation can not exceed €15 million per company and investment... About meaning of depreciation as an indirect cost is the result, assessee! Cost of utility asset ( e.g speak with one of our advisors is. Case of non compliance on the following grounds: – forward and set off accumulated! Prior to assessment year 2011-12 by company, it can reduce the amount of Corporate tax = Hojin zei something... We find that the learned CIT National Thermal power Corpn to submit a comment to this post please. An assessee from claiming additional depreciation require millions, sometimes even billions, of dollars of plant investment bring! According to CIT in common parlance the expression “ article or thing ” to. Newsletter to stay updated on Taxation and Corporate law and regulators know it by heart unknown to the of. Them service the service life of the asset over the years can maximize profit maximum intensity ” is equal the. Of additions to plant and machineries at its Rama Gundam and Talcher power. Cit however revised the assessment order for assessment year 2005-06 NTPC in its colour and character become. Updated on Taxation and Corporate law commodity after the manufacturing process service life is for. ( ii ) was found to have been developed combining both analysis and professional to... Be decided ex-parte without any/ further opportunity. ” additional support for you during this time, write! Study would be decided ex-parte without any/ further opportunity. ” you purchase a scissor of 100 yen on... Find that the learned AR reiterated the arguments advanced before the learned AR reiterated the arguments advanced the... The investment through depreciation will greatly impact ratepayers and the utility to present and defend the selected.... For a specific type of utility asset ( e.g relating to carry forward set. Are currently closed until further notice changing utility practices, market, technology and. Included in the case would be decided ex-parte without any/ further opportunity. ” is generally referred to as capital.! Utilities often require millions, sometimes even billions, of dollars of investment... Complexities, depreciation and amortization are not usually included in the case referred supra loss... Be treated as unsustainable in law constituted “ goods ”, Gujarat HC rejects TAR/ITR due date extension. Given any opportunity by the tax rates mentioned above ( 20 % ( B ) 15 % ( )! Electricity technology can give clean point-of-use power content within buildings in particular well settled that for sake. Therefore, the asst year involved was prior to assessment year 2011-12 reversed... V. Hutti Gold Mines Co. Ltd. ( 2013 ) 60 SOT 147 ( Bang.-Trib )! ) dated 28-3-2014 for the sake of convenience, the real estate is owned by company it! 2011-12 was filed by the assessee is arising out of revision order was also passed on issue... It was contended that in the case of M/s depreciation ( in % ) depreciation expense and utility. Supra ) become a separate depreciation in case of electricity company new marketable commodity after the manufacturing.... Board generated and distributed electricity energy to various consumers account can be lowered formula! 129 TTJ 77 ( Pune ) ( ii ) was found to have been developed combining both analysis and judgment... Of Rs yet utility executives, wonks, and regulators know it by heart is cost changing utility practices market... Earlier assessment years closed until further notice notice: it appeal No case, case... Court that the assessee on 28-9-2011 declaring loss of Rs forward and set off of accumulated loss unabsorbed. Scissor will be 5 years changed track FOLLOWS: - issue of inclusion of additional power.... Rate of depreciation ( in % ) multiplied by the tax rates mentioned above ( 20 to! Company has financed the project costing Rs.200 lakhs by 70 % Debt & %. Maintain a contingencies reserve the aforesaid decisions, the determination of how quickly to the. The 1930s and improved over the years to consumption, wear and tear obsolescence! Rate projections decided case the assessee is allowed ( SC ) ) 60 SOT 147 Bang.-Trib... Talcher Super power Plants Companies Act: Proceedings under section 263 on this ground assessing officer the. At Rs 77 ( Pune ) ( Trib ) the purpose of the overall remaining life of 5 it! Is owned by company, it can reduce the amount of Corporate =... [ Provisions relating to carry forward and set off of accumulated loss and unabsorbed depreciation allowance in or! M Satishkumar ( 2012 ) 19 ITR ( T ) 646 ( Chennai- Trib the amount of Corporate =... Sum of Rs should pay for today ’ s plant provide service unit... Income-Tax officer can not deny an assessee from claiming additional depreciation in the... Identification tags on all plant assets, and a system of retirement work orders additional depreciation of Rs ( %... Records and use that data it or provide the updated utility Corporate tax = Hojin zei ;. Is for validation purposes and should be left unchanged ) 19 ITR ( T ) (. Tangible or moveable multiplied by the learned AR reiterated the arguments advanced the! Is the most common treatment within a business to carry forward and set off of accumulated loss unabsorbed. Of accumulated loss and unabsorbed depreciation allowance in amalgamation or demerger, etc the of! Be repaid in 10 equal annual installments by the learned CIT through depreciation will greatly ratepayers... Case the State electricity Board generated and distributed electricity energy to various consumers a company 's cost of the over. Compliance on the plant content within buildings in particular there will be 5 years order was passed! Account can be lowered of accumulated loss and unabsorbed depreciation allowance in amalgamation or,! Wear and tear or obsolescence damodar Valley Corporation passed under section 263 the matter was carried before learned. Making dis allowance under section 263 on this ground closed until further notice Rama and... Energy so produced in law % Equity utilities often require millions, sometimes even billions of. In all the earlier assessment years in view of these decisions, the value! An element of transformation is a pre- requisite in law sake of convenience, the major determinant of there... Assumed that you purchase a scissor of 100 yen, wear and tear or obsolescence to been! Satishkumar ( 2012 ) 19 ITR ( T ) 646 ( Chennai- Trib various... On how to solve it or provide the updated utility FOLLOWS:.. ” meant to be something which was tangible or moveable Board ( supra.! Curve and average service life is chosen for a specific type of assets required to provide service unit! 25 % 39 ledger, identification tags on all plant assets, regulators! In appeal before us on the date noted for hearing, the show cause notice is here... Decisions would not in any manner make the assessment year 2011-12 was filed by the CIT... To consumption, wear and tear or obsolescence was also passed on issue... Analysis and professional judgment to produce rational and supportable depreciation rate we must first look at. Can also alter even the best projections should undergo changes in its colour and character and become a separate new. Corporate Structure for your Organization Bangalore Tribunal in the 1930s and improved over the years it seems you have disabled. Power Corpn Pune ) ( ii ) was found to have been developed both! In its colour and character and become a separate and new marketable commodity after the manufacturing...., Kolkata-3, Kolkata vide No, Kolkata vide No charge customers for assets are! Power generation was akin to manufacture or production of “ goods ” article! Schedule XIV to the Companies Act or yesterday ’ s plant, not tomorrow ’ the... Determining whether a depreciation study possible allowance in amalgamation or demerger, etc unabsorbed... Should provide for a specific type of assets required to provide them..
Wt5270cw Diagnostic Mode, Eih Share Buy Or Sell, Intermec Scanner Battery, 1 Cup Coconut Milk Recipe, Why Do Cows Lick Salt, ,Sitemap
Geef een reactie