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HC upheld ITAT's decision allowing depreciation on beverages division assets under Section 32, ruling that machinery kept ready for commercial production but unused due to public agitation beyond assessee's control qualifies for depreciation. Court held assets became part of block assets in ongoing business, making depreciation allowable on entire block regardless of individual asset usage. HC also allowed expenditure deduction for cane price differential, finding government orders were received in May-June 2005, making expenditure crystallize in relevant assessment year. Court permitted deduction of excess payments to farmers treated as goodwill, recognizing legitimate business expenditure for uninterrupted sugarcane supply. Consequently, book profit computation under Section 115JB was adjusted favorably for assessee across all disputed issues.
HC upheld ITAT's decision allowing depreciation on beverages division assets under Section 32, ruling that machinery kept ready for commercial production but unused due to public agitation beyond assessee's control qualifies for depreciation. Court held assets became part of block assets in ongoing business, making depreciation allowable on entire block regardless of individual asset usage. HC also allowed expenditure deduction for cane price differential, finding government orders were received in May-June 2005, making expenditure crystallize in relevant assessment year. Court permitted deduction of excess payments to farmers treated as goodwill, recognizing legitimate business expenditure for uninterrupted sugarcane supply. Consequently, book profit computation under Section 115JB was adjusted favorably for assessee across all disputed issues.
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