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
erred in disallowing amount written off towards Loose tools in
profit and loss account amounting to Rs 4,67,37,977/-
The Appellant prays that ... relation to the disallowance
of writing off towards Loose tools be deleted
7. On the facts and circumstances of the case
erred in disallowing amount written off towards Loose tools in
profit and loss account amounting to Rs 4,67,37,977/-
The Appellant prays that ... relation to the disallowance
of writing off towards Loose tools be deleted
7. On the facts and circumstances of the case
next issue relates to the disallowance of expenditure
claimed on loose tools. The assessee has claimed Rs.1,99,96,112/-
as expenditure towards loose ... should have followed systematic method of
inventory management for consumption of loose tools etc and the
expenditure should be claimed on the basis of actual
addition of Rs.5,67,156/-
made on account of loose tools written off when the assessee
failed to substantiate that loss was genuinely claimed ... account of loose tools written off. The assessee in this year has
written off raw material for Rs.18,52,714/- including the loose tools
which disallowance of depreciation of loose tools and dies, amounting to
Rs.3,78,571/-, made by the Assessing Officer, due to the change ... order
that till last year the assessee was writing off the loose tools over a period of two
6
ITA NO.164/Del./2008
