2017 (9) TMI 2024

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....no specific adjudication. 2. Ld. Counsel for the assessee at the outset submitted that he was withdrawing ground No.3. Accordingly, ground No.3 is dismissed as withdrawn. 3. This leaves us with ground No.2, which assails disallowance of additional depreciation claimed by the assessee. 4. The additional depreciation claimed by the assessee was the balance which remained from the claim made for assessment year 2011-12 for plant and machinery used for a period less than 180 days. Assessee had claimed only 50% of the additional depreciation for which it was eligible, since the new plant and machinery on which such depreciation was claimed was put to use for a period less than 180 days in the previous year relevant to assessment year 20....

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....alculated at the percentage prescribed for an asset under clause (iia)for that previous year, then, the deduction for the balance fifty per cent of the amount calculated at the percentage prescribed for such asset under clause (iia) shall be allowed under this subsection in the immediately succeeding previous year in respect of such asset: ......." (Emphasis is ours) 11. We may only indicate that during the course of the arguments, our attention was drawn to the "Memorandum Explaining the provisions in Financial Bill, 2015", whereby, the aforementioned amendment was brought about. 11.1. The relevant part of the Memorandum is extracted hereafter: "..... To remove the discrimination in the matter o....