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Appeal disposed off.The matter needs to be examined afresh for the claim of depreciation by the assessing officer, in the light of the auditor's report providing itemwise accounting of assets and liabilities on 4.12.2015. Thus, the matter is remitted back to the assessing authority to reconsider and verify the records and pass fresh order, as far as claim of depreciation on the assets claimed by the respondent-assessee, pursuant to the Scheme of 2003.

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Section 32 of the Income Tax Act, 1961 — Depreciation — Where erstwhile company was divided and assessee new company received assets under related amalgamation scheme and AO disallowed depreciation on assets as they were unidentifiable, Auditors report received subsequently which provided item wise opening balance was to be taken into consideration for fresh Computation of Depreciation — Commissioner of income tax vs. Poorvanchal Vidyut Vitran Nigam Ltd [2020] 268 Taxman 132 (Allahabad)

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