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Issues: Whether depreciation on two trucks could be disallowed for want of original documentary proof and whether the additional documents produced before the first appellate authority ought to have been considered instead of being rejected on a technical objection under rule 46A.
Analysis: The assessee produced photocopies of the purchase invoice, registration certificate and finance-company certificate before the appellate authority, which prima facie indicated ownership of the trucks. The rejection of those materials solely on the ground of non-compliance with rule 46A was not justified without giving the assessee an to cure the defect. At the same time, the documents were only photocopies, and authenticity had to be verified by production of originals such as the purchase invoice, registration book and insurance papers. The proper course was therefore to remand the matter for verification rather than uphold the disallowance outright.
Conclusion: The matter was remanded to the Assessing Officer for verification of the original documents, and depreciation was to be allowed if ownership of the two trucks was established.
Ratio Decidendi: Additional evidence relevant to ownership of depreciable assets should not be discarded merely on a technical objection under rule 46A when the defect can be cured and the documents require factual verification.