Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
In revision under s. 263, PCIT contended the assessment was erroneous for allowing depreciation on opening WDV without first setting off brought-forward additional depreciation from the preceding year. ITAT reversed, holding there is no statutory requirement to reduce opening WDV by carried-forward additional depreciation before computing current-year depreciation; depreciation is to be computed by applying the prescribed rate to the asset's opening WDV. Consequently, the PCIT's conclusion of error in the AO's assessment was erroneous. The assessment stands as passed, the s. 263 revision direction quashed, and the assessee's appeal is allowed.
In revision under s. 263, PCIT contended the assessment was erroneous for allowing depreciation on opening WDV without first setting off brought-forward additional depreciation from the preceding year. ITAT reversed, holding there is no statutory requirement to reduce opening WDV by carried-forward additional depreciation before computing current-year depreciation; depreciation is to be computed by applying the prescribed rate to the asset's opening WDV. Consequently, the PCIT's conclusion of error in the AO's assessment was erroneous. The assessment stands as passed, the s. 263 revision direction quashed, and the assessee's appeal is allowed.
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