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8. We have heard both the sides on the issue. The assessee is
engaged in the business of trading of Xerographic Equipments,
Printers, Scanners, Faxes, Multi Functional Devices and
consumables parts thereof. The assessee leased out the equipments
to the customers on an operating lease basis and these equipments
are capitalized and depreciation is claimed for tax purposes in
accordance with the provisions of the Act. These operating leased
assets were returned to the assessee either on the termination of the
lease or otherwise after a period of six months, then the assessee is
following a practice to convert these assets into stock-in-trade at a
nominal value of Rs.1/- as these used assets are not having any
readymade market for further leasing. This nominal value is reduced
from the block of assets. In some of the cases, these assets are
again leased out then they are recapitalized in the block of assets at
the nominal value at which these were decapitalised. However,
certain used assets remained in stock-in-trade and whenever these
ITA No. 2060/Del./2015
are sold, the profit is offered for taxation. This method of accounting
is being followed consistently by the assessee. When the assets are
recapitalized at the nominal value at which it is decapitalised then
there is no effect on the taxability of the assessee. Similarly,
whenever these used assets are converted into stock-in-trade and
sold subsequently and the surplus on the sale is offered for taxation
then there is no harm to the revenue. Considering all these facts, we
allow this ground of assessee's appeal.