Court Upholds Reassessment u/s 147 for Depreciation Claims; Invoices Missing for 34% of Claimed Assets.

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....Reopening of assessment u/s 147 - Depreciation u/s 32 on all the assets @ 100% of the assets acquired during the year - The assessee has not admittedly produced the invoices in respect of 34% of the claim of depreciation - The law does not provide for statutory presumption in favour of the statutory audit report. The finding of fact on the aforesaid issue has been recorded by all the authorities viz., the Assessing Officer, Commissioner of Income Tax (Appeals) and the tribunal, which is in conformity with Section 37 of the Act. The aforesaid finding cannot be termed as perverse. - HC....