PCIT's Method of Reducing Brought Forward Additional Depreciation Before Computing Current Year's Depreciation Under Section 32 Rejected

ITAT ruled against PCIT's interpretation of depreciation computation under Section 32(1)(ii) and 43(6)(c). The tribunal rejected PCIT's method requiring brought forward additional depreciation from AY 2017-18 to be first reduced from opening WDV before computing current year's depreciation for AY 2018-19. ITAT affirmed depreciation must be calculated on WDV of block assets per prescribed rates, with WDV computation only adjusted for asset additions and disposals during the year. The tribunal found assessee's depreciation claim aligned with ITR utility format and Tax Audit Report requirements. Since no erroneous treatment prejudicial to revenue interest was established, assessee's appeal was allowed, invalidating revision under s.263. .....

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