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    <title>2025 (8) TMI 279 - ITAT VISAKHAPATNAM</title>
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    <description>The ITAT Visakhapatnam allowed the revenue&#039;s appeal disallowing depreciation claimed by the assessee. The tribunal found no evidence that the machinery was put to use or installed during the assessment year, as raw materials were only included in capital work-in-progress without allocation to fixed assets. The assessee failed to produce an installation certificate and inauguration expenses were held insufficient to prove commencement of business. Consequently, the assessee was not considered a passive user of the assets, and depreciation was rightly disallowed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=776092</link>
      <description>The ITAT Visakhapatnam allowed the revenue&#039;s appeal disallowing depreciation claimed by the assessee. The tribunal found no evidence that the machinery was put to use or installed during the assessment year, as raw materials were only included in capital work-in-progress without allocation to fixed assets. The assessee failed to produce an installation certificate and inauguration expenses were held insufficient to prove commencement of business. Consequently, the assessee was not considered a passive user of the assets, and depreciation was rightly disallowed.</description>
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