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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 capitalised 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 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."