Shuttering is a plant, not a temporary erection – 100% claim disallowed – CIT(A)’s liberal view reversed – ITAT restores AO’s 15%

DCIT Vs Jai Jai Ram Singh Infrastructure Private Ltd. (ITAT Delhi) Revenue challenged the order of CIT(A), whereby the CIT(A) had directed AO to allow 100% depreciation on shuttering material treating it as a purely temporary wooden structure. Assessee, an infrastructure company engaged in construction contracts, had originally claimed ₹3.03 crore as shuttering material cost in its Profit & Loss account. During reassessment,e AO treated the same as capital expenditure, capitalised it, & allowed 15% depreciation, thereby making an addition of ₹2.57 crore over the assessed income. CI...