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Issues: Whether the assessee was entitled to depreciation on market research expenses and whether the matter required restoration to the Assessing Officer for giving effect to the Dispute Resolution Panel's directions.
Analysis: The assessee had claimed depreciation on the capitalised market research expenses, relying on the Dispute Resolution Panel's finding that such claim had been allowed in the preceding year. The Dispute Resolution Panel had directed the Assessing Officer to grant depreciation after necessary verification, but the assessment order did not give effect to that direction. In view of the material on record, the issue was fit to be restored to the Assessing Officer for implementation of the directions already issued by the Dispute Resolution Panel.
Conclusion: The issue was restored to the Assessing Officer for verification and for giving effect to the direction to allow depreciation on the market research expenses.
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