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The transaction of acquisition business as a going concern is between two related parties and the seller had a substantial interest by holding 50% share. The assets were already depreciated in the hands of the seller i.e. M/s.BPL Ltd., higher values were assigned by the assessee-company in order to avoid tax liability - AO is justified in his action in restricting the allowance of depreciation on WDV at higher than 25% of the closing stock.
The transaction of acquisition business as a going concern is between two related parties and the seller had a substantial interest by holding 50% share. The assets were already depreciated in the hands of the seller i.e. M/s.BPL Ltd., higher values were assigned by the assessee-company in order to avoid tax liability - AO is justified in his action in restricting the allowance of depreciation on WDV at higher than 25% of the closing stock.
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