Carried forward depreciation claim restored for fresh consideration on verification of the record and governing set-off principle.

Carried forward depreciation can be set off even where no business activity is carried on in a year, and the Tribunal therefore directed fresh examination of the assessee's depreciation claim on the basis of material to be furnished before the Assessing Officer. The entitlement was not finally decided on the existing record; instead, the depreciation issue was restored for reconsideration, with the miscellaneous applications allowed for statistical purposes.

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Issues: Whether the assessee's claim for carried forward depreciation was required to be restored to the Assessing Officer for fresh consideration.

Analysis: The assessee sought rectification on the ground that its entitlement to depreciation had been accepted and that the factual verification of the depreciation claim could be made from the record before the Assessing Officer. The Tribunal noted that, even where no activity is carried on in a year, carried forward depreciation from earlier years can be set off, and therefore considered it to revisit the claim in the light of the material to be furnished by the assessee and the governing principle.

Conclusion: The issue of depreciation was restored to the Assessing Officer for decision afresh, and the miscellaneous applications were allowed for statistical purposes.

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