Mumbai Court October 1979 Judgments

income-tax Officer Vs. Vickers Sperry of India

Court: Income Tax Appellate Tribunal ITAT Mumbai

Reported in: (1983)3ITD739(Mum.)

1. The first and the main issue in these two appeals is whether the assessee is or not entitled to depreciation under Section 32(1) on scientific research assets relating to the business carried on by it, the cost of which has been allowed as deduction in full under Section 35(1)(iv)/35(2)(ia) in the earlier year. Long and elaborate arguments were advanced by the counsels on the two sides and by those who appeared as interveners on behalf of their respective clients. In fact the hearing continued for three days. While for the sake of brevity, we do not propose to refer to their individual arguments in detail and will be dealing with them in the course of our judgment, we would like to express our appreciation of the disciplined manner in which the counsels made their respective submissions and for the contribution made and the assistance rendered by them.2. Briefly stated, the relevant facts are that the assessee, a company carried on extensive business of manufacture and sale of hydr...