Depreciation on Resorts allowable for full year despite having seasonal business

Niyant Heritage Hotels [P] Ltd Vs I.T.O (ITAT Delhi) There Is no dispute that the assessee is running a resort at Raj Niwas Palace, Dholpur. It Is also not In dispute that being a tourist place, the occupancy is not throughout the year but only in seasons favourable to the tourists. Therefore, basis the revenue of some months, it cannot be construed that the asset was used only for less than 180 days. We, therefore, direct the Assessing Officer to allow depreciation for entire year. FULL TEXT OF THE ORDER OF ITAT DELHI This appeal by the assessee is preferred against the order of the CIT[A]- ...