Section 32 & 271(1)(c) of the Income-tax Act, 1961—Depreciation— Tribunal is correct in holding that the issue of depreciation on Intellectual Property Rights could not be made subject matter of assessment u/S. 153A without appreciating the fact the director of the assessee company had in his statement u/S. 132(4) during the course of the search withdrawn the claim of depreciation on IPRs and hence, the assessee was not liable for penalty in view of provisions of Section 271(1)(c) as mere fact that the claim was withdrawn during the search would not give rise to the penalty. - PR. CIT V/s FINANCIAL TECHNOLOGIES INDIA LTD. - [2018] 8 ITCD Online 76 (BOM)