Depreciation cost basis follows the successor owner's takeover value, not the predecessor's original asset cost.

Depreciation under Section 10(2)(vi) of the Indian Income-tax Act, 1922 was construed by reference to the cost to the assessee who owns the asset and is chargeable to tax. The phrase "original cost thereof to the assessee" was given its ordinary meaning, so the relevant depreciation base was the value at which the successor company took over the assets, not the predecessor companies' original acquisition cost. A construction that would import the predecessor's cost was rejected as adding words not found in the statute, and the proviso's aggregate limitation did not alter the meaning of the charging language.

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Issues: Whether depreciation allowance under Section 10(2)(vi) of the Indian Income-tax Act, 1922, for assets acquired by a successor company must be computed with reference to the original cost of those assets to the predecessor companies or with reference to the cost at which the successor company took them over.

Analysis: The words "original cost thereof to the assessee" were construed according to their ordinary and natural meaning. The expression "assessee" was taken to mean the person who owns the property and is chargeable to tax, and therefore the relevant cost for depreciation is the cost to that person, not to previous owners. The construction that would substitute the predecessor's cost was rejected as adding words not found in the statute. The definition of "assessee" in Section 2(2) supported this reading, and the aggregate limitation in the proviso did not alter the meaning of the charging language.

Conclusion: Depreciation had to be computed on the value at which the assets were taken over by the company, and not on the original cost to the predecessor companies.

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