Right to Collect Toll’ Eligible for Depreciation as ‘Intangible Asset’

DCIT Vs Ashoka Dhankuni Kharagpur Tollway Ltd (ITAT Pune) Revenue’s sole substantive grievance raised in the instant appeal challenges correctness of the CIT(A)’s action reversing assessment findings dated 21.12.2019 disallowing the assessee’s depreciation claim amounting to Rs.3,47,61,85,194,/- pertaining to its ‘right to collect toll’ as an intangible asset under section 32(1)(ii) of the Act. The Assessing Officer appears to have amortized the assessee’s corresponding amount as per the CBDT’s circular issued on 09/2014. The CIT(A) on the other hand has adopted judicial ...