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Issues involved:
The issues involved in the judgment are the determination of substantial questions of law u/s 260A of the Income Tax Act, 1961 for assessment year 1994-95. Issue [A]: The first issue pertains to whether the Appellate Tribunal was correct in allowing depreciation at a higher rate of 40% for assets given on lease by the assessee. The Revenue filed a Tax Appeal challenging this decision. The Court formulated the substantial question of law for consideration based on the Revenue's submission. Issue [B]: The second issue concerns the depreciation claim of the assessee in relation to vehicles registered in the names of the directors instead of the assessee company. The Tribunal found that the vehicles were owned by the company, even though registered in the directors' names, and the lease rent was received by the company. As this was a factual finding, the Tribunal upheld the claim for depreciation. Consequently, the Court determined that no substantial question of law arose regarding this issue. The Court directed the filing of any additional Paper-Book within three months and scheduled the matter to be heard along with another Tax Appeal related to the same assessee from a previous year.
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