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TMI Blog2019 (11) TMI 212X X X X Extracts X X X X X X X X Extracts X X X X ..... them on hire - Tribunal rejected revenue appeal - HELD THAT:- AO disallowed the depreciation holding that this would be applicable only to such businesses who had taken the buses on hire - Tribunal having dismissed the appeal of the Revenue, it is before us in these appeals. A bare perusal of item No.III (3) (ii) quoted above makes it clear that the interpretation given by the Commissioner and t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hose automobiles are meant for their use. We are not able to find any fault with the judgment and orders of the Tribunal. No other question of law arises. - ITA No. 101 of 2018 (O&M), ITA No.102 of 2018 (O&M), ITA No.109 of 2018 (O&M) And ITA No.170 of 2018 (O&M) - - - Dated:- 22-7-2019 - JUSTICE AJAY TEWARI AND JUSTICE HARNARESH SINGH GILL For The Appellant : Mr. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... inst the order of the Income Tax Appellate Tribunal Division Bench Amritsar, dated 18.09.2017 in ITA No.503(Asr)/2016 for the Assessment Year 2013- 2014. 4. ITA No.170 of 2018 has been filed under Section 260A of the Income Tax Act, 1961 (for short 'the Act') against the order of the Income Tax Appellate Tribunal Division Bench Amritsar, dated 23.08.2017 in ITA No.426 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 8. The Assessing Officer disallowed the depreciation holding that this would be applicable only to such businesses who had taken the buses on hire. Thus the manner in which the Assessing Officer read the provision would be as follows :- 'Motor buses, motor lorries and motor taxis on hire used in a business of running them.' 9. The Ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for hire because in every other case such vehicles would be only utilized for use of assessee and not for a business. Thus the natural meaning of the phrase would apply in the present case and those Assessees who are running automobiles for hire would be liable to claim a higher depreciation than those whose automobiles are meant for their use. 10. In the circumstances of the ca ..... X X X X Extracts X X X X X X X X Extracts X X X X
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