Higher depreciation claim on CNC drill machines remanded for fresh factual examination of asset use and classification.

Entitlement to higher depreciation on CNC drill machines depended on unresolved factual questions about the asset's character and use, including whether it was itself an agricultural and municipal waste conversion device or machinery used to manufacture such devices. Because the record did not clearly establish the correct depreciation category, the issue required fresh examination on the basis of documents and evidence to be furnished by the assessee. The disallowance was set aside and the matter was remanded to the Assessing Officer for de novo adjudication after giving a reasonable opportunity to the assessee.

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Issues: Whether the assessee's claim of 80% depreciation on CNC drill machines required fresh examination and whether the matter should be remanded to the Assessing Officer for de novo adjudication.

Analysis: The claim for higher depreciation depended on whether the CNC drill machine was itself an agricultural and municipal waste conversion device, whether it was machinery used to manufacture such devices, or whether it was eligible only for normal depreciation with additional depreciation. The material on record did not clearly establish the correct category of the asset or the precise nature of its use. Since the factual foundation for deciding the correct depreciation rate was incomplete, the issue required re-examination on the basis of the documents and evidence to be furnished by the assessee.

Conclusion: The disallowance was set aside and the matter was remanded to the Assessing Officer for fresh adjudication after granting reasonable opportunity to the assessee.

Ratio Decidendi: Where entitlement to higher depreciation turns on unresolved factual questions about the nature and use of the asset, the matter should be restored for fresh determination on evidence.

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