Depreciation allowed in earlier year cannot be disallowed later alleging non-generation of revenue

DCIT Vs Rapipay Finvest P. Ltd (ITAT Delhi)

ITAT Delhi held that it is fact that depreciation on software/ machinery was claimed and duly allowed in F.Y. 2012-2013. However, due to uncertainty of business revenue could not be generated by using the software in F.Y. 2013-14. Accordingly, depreciation cannot be disallowed alleging non-generation of revenue.

Facts-

The Assessee company was incorporated on 06.01.2009 and carrying on the activity of providing IT enables services and BPO services and have shown purchase and sale of “printed books of voter list” from M/s. Vakrangee Software Ltd and M/s. Mindtree Export Pvt. Ltd amounting to Rs. 2,76,75,720/- and Rs. 2,84,57,520/- respectively. Therefore, in order to verify the identity and creditworthiness of the parties and confirm the genuineness of the transaction, issued the notices u/s 133(6) to the said companies on 24.11.2015 and 07.01.2016 at the address mentioned on their bills/ vouchers.

AO alleging that assessee failed to discharge onus of purchases shown from M/s. Vakrangee Software Ltd., the amount of Rs. 2,76,75,720/- is added back to the taxable income of the assessee as bogus purchase.

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