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
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
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
assessment year 2006-07 stand allowed."
6. The issue of loose tools mentioned in Sl.No. 5 is involved only in
three years ... Assessing Officer in holding the expenditure with
respect to loose tools as being capital in nature and allowing
depreciation @25% thereon. A perusal
disallowance of Rs. 8,15,64,200 being the amount of loose tools charged off. It appears that as per the policy of the company ... loose tools costing below Rs. 10,000 are charged to the P&L a/c, since they are normally consumed in the year
percentage of total cost. This also included
cost of spare parts, loose tools, consumption, sub-contractor charges, gas turbine
services, charges etc. Our attention
inventory has been
shown for Rs. 2003965.20 which consists of loose tools, newsprint,
glazed paper and others. The AO has made the addition only ... assessee company had shown inventory of Rs.
2003965/- consisting of loose tools, new prints and glaze
paper in the balance sheet. The only basis
inventories were in the nature of stores/spares, LDO and loose tools;
that the assets were in the custody of the Liquidator
Next ground is against deletion of disallowance of claim for loose tools amounting to Rs. 2,22,097/-.
(iv) Next ground of the Revenue
