Year
A. Current Assets :
....
1. Inventories :
(a) Stores and Spares
....
....
(b) Loose Tools
....
(c) Stock-in-trade
....
....
Finished Goods
....
....
Work-in-progress
....
....
Raw Materials
Government Secured by.
5. CURRENT ASSETS :- (a) Stores & Spares (b) Loose Tools (At cost or.....) (c)Stock in Trade (d) Warehousing & other charges
Apart
from this, the assessee had claimed amortization of loose tools
amounting to Rs. 55,036/- as being allowable over a period of
three years ... further erred in law and in
facts in holding the loose tools amounting to Rs.
55,036/- to be of capital nature and accordingly
upholding
disallowing the claim of write off of loose tools. For this, assessee has
raised following ground nos. 4 and 5:
"4. For that ... unjustified in disallowing the claim for write off of loose tools amounting to Rs.23.63
lacs.
5. For that on the facts
addition made by Assessing
Officer on account of valuation of loose tools.
3. On the facts and circumstances of the case ... accounting policy in respect of writing off of the loose tools from
a period of three years to one year. The opening inventory of loose
facts of the case in upholding the
disallowance of depreciation on loose tools amounting to Rs.48,67,394 ignoring the
fact that the assessing ... officer has treated the expenditure on loose tools as capital
expenditure in earlier years and added the same to taxable income.
2(b) The learned
this appeal is with regard to allow depreciation at 30% on loose tools when there is no specific rate allowed as such under ... subsequent years, the AO noticed that the non usable items represent loose tools, which, according to the AO was capital in nature but with very
against the assessee.
34. During the assessment year, the company acquired loose tools worth Rs. 24,401 (apart from other equipment) for the running ... disallowed the rebate thereon on the ground that the items being loose tools were not machinery or plant and, therefore, the company was entitled only
show what amount would be required annually to replace loose tools. furniture, moulds, motor cars, laboratory equipment, etc. According to this statement ... replacement is required to be made in the case of loose tools, furniture, etc., because it appears from the assessment orders filed by the company
that the type metal in molten form could be treated as loose tools and, therefore, the treatment of such metal as had been done ... year would be a distorted one. Even on the analogy of loose tools, learned standing counsel submitted, that in view of the text book
