https://www.taxtmi.com/caselaws?id=13840 Where accounts were rejected and income was computed by best judgment assessment by applying a flat net profit rate on contract receipts, the dominant issue was whether depreciation on machinery used in execution of works stood automatically absorbed in the net profit rate. The HC held that, under s.119, CBDT circulars binding on tax authorities required separate consideration of a specific depreciation claim made with particulars under s.32, and such consideration must be apparent from the assessment order; it cannot be presumed. For periods prior to 1 April 1994, fixing a net profit rate does not deem depreciation to have been allowed. Consequently, the ITAT majority view was upheld and the assessees' appeals were allowed. en-us Thu, 20 Sep 2001 00:00:00 +0530 Mon, 22 Dec 2025 21:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=13840 Where accounts were rejected and income was computed by best judgment assessment by applying a flat net profit rate on contract receipts, the dominant issue was whether depreciation on machinery used in execution of works stood automatically absorbed in the net profit rate. The HC held that, under s.119, CBDT circulars binding on tax authorities required separate consideration of a specific depreciation claim made with particulars under s.32, and such consideration must be apparent from the assessment order; it cannot be presumed. For periods prior to 1 April 1994, fixing a net profit rate does not deem depreciation to have been allowed. Consequently, the ITAT majority view was upheld and the assessees' appeals were allowed. Case-Laws Income Tax Thu, 20 Sep 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=13840