Procedural compliance for additional depreciation is satisfied when Form 3AA is filed during assessment before final order, not necessarily with return.

Filing Form 3AA during assessment proceedings, even though it was not enclosed with the return, constituted sufficient procedural compliance for claiming additional depreciation. The claim itself was not disputed on merits; the objection related only to timing of the form. Because the form was furnished before the assessment order was finalised, the statutory requirement was met in substance and the objection to the allowance failed.

---

---

Issues: Whether filing Form 3AA during the assessment proceedings, but not along with the return of income, was sufficient compliance for claiming additional depreciation.

Analysis: The claim for additional depreciation was not disputed on merits. The only objection was that Form 3AA had not accompanied the return. The form was, however, furnished during the assessment proceedings before the assessment order was finalised, and that satisfied the procedural requirement in substance.

Conclusion: Filing Form 3AA during the assessment proceedings amounted to sufficient compliance. The objection to the claim of additional depreciation failed.

Ratio Decidendi: Procedural compliance for a tax deduction or allowance is sufficient when the requisite form is furnished during assessment proceedings before final assessment, provided the substantive entitlement is otherwise undisputed.

---