https://www.taxtmi.com/caselaws?id=752538 The ITAT PUNE ruled against revenue's appeal challenging depreciation allowance on a Honda City car. The AO had restricted depreciation to 50% under Rule 5 of Income Tax Rules, 1962, but the tribunal found this constituted an impermissible change of opinion citing Kelvinator of India Limited precedent. The reopening under section 147 was initiated beyond four years without establishing non-disclosure by the assessee. The tribunal noted the vehicle was insured and put to use on 30.09.2009, supporting the assessee's claim. The appeal was decided against revenue on both jurisdictional and merit grounds. en-us Fri, 10 May 2024 00:00:00 +0530 Mon, 13 May 2024 08:38:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752538 The ITAT PUNE ruled against revenue's appeal challenging depreciation allowance on a Honda City car. The AO had restricted depreciation to 50% under Rule 5 of Income Tax Rules, 1962, but the tribunal found this constituted an impermissible change of opinion citing Kelvinator of India Limited precedent. The reopening under section 147 was initiated beyond four years without establishing non-disclosure by the assessee. The tribunal noted the vehicle was insured and put to use on 30.09.2009, supporting the assessee's claim. The appeal was decided against revenue on both jurisdictional and merit grounds. Case-Laws Income Tax Fri, 10 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752538