Case Law Details
SDS Ramcides Crop Science Pvt. Ltd Vs DCIT (ITAT Chennai)
Introduction: Dive into the intricacies of the dispute between SDS Ramcides Crop Science Pvt. Ltd and DCIT, as the Income Tax Appellate Tribunal (ITAT) Chennai addresses the controversy surrounding the disallowance of depreciation. The case revolves around the refurbishment of the assessee’s leasehold premises and the ensuing claim of 100% depreciation on specific temporary structures.
Detailed Analysis: The article provides a detailed analysis of the facts presented by the counsel for the assessee, highlighting the key contention that the Assessing Officer incorrectly assumed a 100% depreciation claim on the total amount of Rs. 1,26,20,410/-. The actual claim, as clarified, was for 50% of the amount, i.e., Rs. 63,10,205/-, in consideration of specific assets put to use from 25.03.2014. The Assessing Officer’s erroneous disallowance of the entire amount and subsequent rectification by the CIT(A) form critical points in the analysis.
The tribunal’s intervention and resolution of the depreciation dispute are examined in detail. The article elucidates the correct application of depreciation at 100%, albeit limited to 50% due to the asset’s utilization from 25.03.2014. The inability of the LD. DR to counter the presented facts, despite specific queries, adds weight to the assesse’s claim.
Conclusion: The article concludes by summarizing the ITAT’s decision, emphasizing the allowance of the assessee’s claim for depreciation. The tribunal’s correction of the initial miscalculation by the Assessing Officer and the subsequent affirmation of the rightful depreciation claim at 50% provide clarity on this aspect of the SDS Ramcides Crop Science vs. DCIT case.
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