https://www.taxtmi.com/caselaws?id=775429 ITAT Delhi held that revision under section 263 was not justified as there were two plausible views regarding depreciation and inclusion of negative grant in asset cost. The AO's allowance of depreciation on the opening WDV plus capital expenditure was supported by precedent, and the Pr. CIT's contrary view did not warrant interference. The CBDT circular No. 09/2014 was held inapplicable retrospectively, thus not affecting the assessment year in question. The negative grant payable to NHAI, though due from the 15th year, was an ascertained liability accrued on project completion and properly included in the asset cost under the mercantile system. The Pr. CIT erred in directing its deletion. The ITAT set aside the revision order and allowed the appeal, affirming the assessee's claim for depreciation and inclusion of the negative grant. en-us Tue, 22 Jul 2025 00:00:00 +0530 Fri, 25 Jul 2025 08:28:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775429 ITAT Delhi held that revision under section 263 was not justified as there were two plausible views regarding depreciation and inclusion of negative grant in asset cost. The AO's allowance of depreciation on the opening WDV plus capital expenditure was supported by precedent, and the Pr. CIT's contrary view did not warrant interference. The CBDT circular No. 09/2014 was held inapplicable retrospectively, thus not affecting the assessment year in question. The negative grant payable to NHAI, though due from the 15th year, was an ascertained liability accrued on project completion and properly included in the asset cost under the mercantile system. The Pr. CIT erred in directing its deletion. The ITAT set aside the revision order and allowed the appeal, affirming the assessee's claim for depreciation and inclusion of the negative grant. Case-Laws Income Tax Tue, 22 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775429