Depreciation on rented assets upheld where prior years were identical and no material difference was shown.

Depreciation on rented assets was held admissible where the Revenue failed to show any material difference from earlier years, and the Tribunal applied the settled principle that depreciation is allowable when the asset is used for the purpose of the assessee's business. As the factual matrix was identical to prior years and no distinguishing feature was shown, the disallowance was deleted and the Revenue's challenge failed.

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Issues: Whether depreciation claimed on rented assets was admissible when the Assessing Officer disallowed it on the ground that the assets were not used for the assessee's own business.

Analysis: The Tribunal noted that the disallowance had already been deleted in the assessee's own earlier years and that the factual matrix was stated to be identical. It relied on the settled principle that depreciation is allowable where the asset is used for the purpose of the assessee's business, and found no distinguishing feature to depart from the earlier view. Since the Revenue could not show any material difference, the deletion of the disallowance was upheld.

Conclusion: The depreciation claim was held admissible and the Revenue's challenge failed.

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