Section 32 read with section 271(1)(c) of the Income Tax Act, 1961 — Depreciation — Proceedings for penalty under section 271(1)(c) were initiated against assessee for raising a wrong claim of depreciation in respect of contract awarded for broadening of National Highway on Build Operate Transfer basis on ground that road was not owned by assessee, in view of fact that various assessees in similar circumstances had claimed depreciation and in order to reduce said controversy, Board had issued Circular No. 9, dated 23-04-2014. assessee could not be held guilty of furnishing inaccurate particulars of income and thus, impugned proceedings deserved to be set aside— Principal Commissioner of income tax vs. Himalayan Expressway Ltd. [2019] 267 Taxman 364 (Punjab & Haryana)