Saturday, December 23, 2017

Income assessed as charitable on assets used, still depreciation can be claimed??

CIT vs. Rajasthan And Gujarati Charitable Foundation Poona (Supreme Court) - 22 Dec 2017


Some of the important references of the case (for easy reference only)-


1- The first question which requires consideration by this Court is: whether depreciation was allowable on the assets, the cost of which has been fully allowed as application of income under section 11 in the past years,

2- That, section 32(1) of the Act provides for depreciation in respect of building, plant and machinery owned by the assessee and used for business purposes.

3- section 32 of the Income Tax Act providing for depreciation for computation of income derived from business or profession is not applicable

4- It may also be mentioned at this stage that the legislature, realising that there was no specific provision in this behalf in the Income Tax Act, has made amendment in Section 11(6) of the Act vide Finance Act No. 2/2014 which became effective from the Assessment Year 2015-2016.

The Delhi High Court has taken the view and rightly so, that the said amendment is prospective in nature, It also follows that once assessee is allowed depreciation, he shall be entitled to carry forward the depreciation as well


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