The Income Tax Appellate Tribunal (ITAT), Ahmedabad bench, while dismissing the appeal filed by the assessee, observed that the assessee failed to provide details for the commissioning of assets on different dates to compute correct depreciation.
The assessee, Dakshin Gujarat Vij. Co. Ltd, is an undertaking of the Government of Gujarat and came into existence during the reorganization of the erstwhile Gujarat Electricity Board (GEB). The assessee company is engaged in the activity of power distribution.
During the assessment proceedings, the Assessing Officer (AO) disallowed the claim of depreciation on fixed assets purchased on 31st March 2006 for the year under consideration, reasoning that the assets were not put to use in the same year.
Aggrieved, the assessee filed an appeal before the CIT(A), who dismissed the appeal. The assessee then filed another appeal before the tribunal.
M.K. Patel, Counsel for the assessee, argued that during the year under consideration, more than 1000 assets were added on different dates. However, for presentation purposes, assets commissioned and put to use for more than 180 days were entered as of 30th September 2005 in the assets register. Similarly, assets commissioned and put to use for less than 180 days were entered on 31st March 2006.
Kamlesh Makwana, Counsel for Revenue, supported the decision of the lower authorities.
After reviewing the facts and records, the two-member bench of Waseem Ahmed (Accountant Member) and Suchitra Kamble (Judicial Member) observed that to adjudicate the issue, the assessee has to provide details regarding the commissioning of assets on different dates before the AO to compute the correct depreciation. Therefore, the assessee failed to produce the necessary documents.
Consequently, the bench dismissed the appeal of the assessee.
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