Depreciation claim on solar assets must be substantiated; unproved facts can justify revision under section 263.

The Tribunal noted that the assessee claimed depreciation on solar power generation system assets on the basis that they were purchased, installed and put to use during the relevant year, with substantial payment also said to have been made. As no supporting evidence was produced to substantiate purchase, installation, use or payment, the Tribunal found no basis to disturb the Principal Commissioner's view that the assessment order was erroneous and prejudicial to the interests of revenue. The revisionary order under section 263 was therefore sustained, and the assessee's challenge failed.

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Issues: Whether the revisionary order under section 263 of the Income-tax Act, 1961, revising the assessment on the depreciation claim relating to the solar power generation system, was sustainable in the absence of supporting evidence from the assessee.

Analysis: The assessee asserted that the solar generators were purchased, installed and put to use during the relevant financial year and that substantial payment was also made within that year. No supporting evidence was produced before the Tribunal to establish purchase, installation, put to use, or payment as claimed. In the absence of such evidence, the Tribunal found no reason to interfere with the Principal Commissioner's conclusion that the assessment order had been validly revised under section 263.

Conclusion: The revision under section 263 was upheld and the challenge to it failed.

Final Conclusion: The assessment revision stood sustained and the assessee's appeal was rejected.

Ratio Decidendi: Where the assessee does not substantiate the factual basis of a depreciation claim, the revisionary jurisdiction under section 263 can be sustained if the assessment order is found to be erroneous and prejudicial to the interests of revenue.

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