New Rampgreen Technologies Pvt. Ltd. Vs ITO (ITAT Mumbai)
Income Tax Appellate Tribunal (ITAT) Mumbai has issued a significant ruling in the case of New Rampgreen Technologies Pvt. Ltd. against the Income Tax Officer (ITO), primarily addressing disputes over depreciation claims and the validity of reassessment proceedings. The Tribunal’s order, pronounced on June 20, 2025, sided with the appellant on both contested grounds.
The core of the dispute originated from an assessment reopened by the Revenue under Section 148 of the Income Tax Act, 1961, alleging escapement of income due to an asserted claim of excess depreciation by New Rampgreen Technologies Pvt. Ltd. The Income Tax Officer (AO) contended that the company was eligible for only 50% of the normal depreciation entitlement for the relevant assessment year, arguing that the asset—an office premises—was ‘put to use’ for less than 180 days within the financial year.
According to the assessment order, the appellant initially did not respond to the Section 148 notice. Subsequently, the AO issued notices under Section 142(1), to which the company responded on September 28, 2021. New Rampgreen Technologies Pvt. Ltd. informed the AO of the purchase of office premises for Rs. 7.6 crores, with an initial payment of Rs. 1.5 crore made on May 6, 2014, and the balance of Rs. 6 crore settled on January 27, 2015. Based on the latter payment date, the AO proceeded to disallow 50% of the depreciation claimed, asserting the asset’s use for less than 180 days.
