The HC ruled that expenditure on machinery replacement was ...

Machinery replacement costs deemed revenue expenditure; fly ash silos qualify for 100% depreciation as pollution control equipment

March 21, 2025

Case Laws     Income Tax     HC

The HC ruled that expenditure on machinery replacement was revenue in nature as production capacity remained constant across factories. While benefits under Section 35(i)(iv) were denied following precedent, the court granted 100% depreciation for fly ash silos as pollution control equipment since they effectively contained and evacuated pollutants by channeling fly ash into production processes. The assessee's claim for interest deduction under Section 43B failed due to lack of evidence proving actual payment. Regarding Section 80HHC deductions, the court ruled in the assessee's favor, holding that excise duty, customs duty, and windmill power receipts form part of total turnover. However, the claim for full depreciation on dumpers was rejected as the assessee failed to prove possession or use prior to October 1, 1995.

View Source