Commr.Of Income Tax,Dibrugarh vs Doom Dooma India Ltd

The Supreme Court addressed the interpretation of 'depreciation actually allowed' under Section 43(6)(b) of the Income-tax Act, 1961, determining that for the assessment years in question, only 40% of the depreciation should be deducted from the opening 'written down value' of assets used in the tea business, rather than the 100% claimed by the Assessing Officer. The Court upheld the Tribunal's decision, which was based on the precedent set in Commissioner of Income-tax v. Suman Tea and Plywood Industries (P) Ltd., affirming that the calculation of depreciation must align with the proportion of income chargeable under Section 28. The appeals by the Department were dismissed, affirming the lower court's ruling.