I am a finance company. I bought the vehicles, I lease them to my customers, and the customer is shown as the owner in the registration certificate. The assessing officer says that makes the customer the owner and refuses me depreciation. Is he right?
No. The Supreme Court held that the lessor, not the lessee, is entitled to depreciation on vehicles leased out in the course of a leasing business. Two conditions have to be met under section 32 - ownership and use for the purposes of the business - and the Court held both were satisfied. On ownership, the lease agreement provided that the assets remain at all times the sole and exclusive property of the lessor, and the lessor kept the right to repossess, to inspect and to require the vehicles back; the entry of the lessee as owner in the registration certificate does not displace that, because section 2(30) of the Motor Vehicles Act is a deeming provision creating a fiction of ownership in favour of the lessee only for the purposes of that Act. As long as the assessee has a right to retain the legal title of the vehicle against the rest of the world, it is the owner in the eyes of law. On use, the Court held that section 32 requires the asset to be used for the purposes of business but does not require the assessee to use it himself; leasing was this assessee's business and the lease income was its business income. The Court went further and held the assessee entitled to the higher rate as well, because its main activity was leasing out or hiring the vehicles. The appeals were allowed and the High Court's judgments set aside.
Decided by the Supreme Court (Supreme Court of India - D.K. Jain and Jagdish Singh Khehar JJ) on 2013-01-14, reported as [2013] 350 ITR 527 (SC). It bears on section 32, section Motor Vehicles Act s.2(30), section 33 (Act of 2025) of the Income Tax Act 1961, in Deductions & Disallowances and How Tax Law Is Read matters.
Leasing sits on a fault line between two ways of describing the same transaction. In law the lessor owns the asset and lets it out. In accounting, and in the commercial sense the parties themselves often use, a finance lease is a loan with the asset as security, and the lessee capitalises it. Depreciation follows ownership under section 32, so which description the assessing officer adopts decides who gets the allowance - and on a fleet financed over several years the allowance is the whole economics of the deal. This is the judgment that settles which description the Act uses. Ownership is legal title under the documents, tested by whether the claimant can hold the title against the rest of the world, and it is not displaced by an entry in a register maintained for a different statute's purposes. The second holding is the one that gets less attention and does more work. Section 32 asks whether the asset was used for the purposes of the business, not whether the assessee personally used it. That sentence reaches well past vehicle leasing: it is the answer wherever an assessee owns an asset that someone else physically operates, provided the letting is the assessee's business and the income from it is assessed as business income. Where the case is over-read is on substance. The Court decided on the lease terms before it and on a record that showed nobody else had claimed the depreciation. It is not authority that a transaction can never be looked through, and an officer who produces a lessee's own depreciation claim on the same asset has taken the case outside what was decided.
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The appellant was a non-banking finance company whose business included leasing. It bought vehicles, including trucks, from the manufacturers and leased them to its customers. The lease agreements provided that the assets would at all times remain the sole and exclusive property of the lessor, and gave the lessor rights of repossession and inspection and a right to have the vehicles returned. Under the Motor Vehicles Act the lessees were entered as the owners in the registration certificates. The company claimed depreciation on the leased vehicles, and claimed it at the higher rate of fifty per cent applicable to motor vehicles used in a business of running them on hire. The Commissioner (Appeals) took the view that the company had only financed the purchase of the trucks, so that leasing or hiring them out did not amount to carrying on the business of hiring trucks, and that the company had to use the trucks in its own business of running them on hire before it could claim the higher rate. The Appellate Tribunal held that the assessee, having used the trucks for the purpose of business, was entitled to depreciation at the higher rate on the trucks leased out by it. The High Court of Karnataka reversed the Tribunal. The company came to the Supreme Court in Civil Appeals Nos. 3282, 3286, 3287, 3288, 3289 and 3290 of 2008.
The High Court erred in law in reversing the Tribunal. In its concluding paragraph the Court said: "For the foregoing reasons, in our opinion, the High Court erred in law in reversing the decision of the Tribunal. Consequently, the appeals are allowed; the impugned judgments are set aside and the substantial questions of law framed by the High Court, extracted in para 7 (supra), are answered in favour of the assessee and against the Revenue. There will, however, be no order as to costs." The questions so answered were whether the assessee is the owner of the vehicles leased out to its customers and whether it is entitled to the higher rate of depreciation on them. On ownership, the Court held that section 2(30) of the Motor Vehicles Act is a deeming provision creating a legal fiction of ownership in favour of the lessee only for the purposes of that Act, and that as long as the assessee has a right to retain the legal title of the vehicle against the rest of the world it is the owner of the vehicle in the eyes of law. On use, it held that section 32 requires the assessee to use the asset for the purposes of business and does not mandate usage of the asset by the assessee itself, so that a lessor whose business is leasing, and whose lease income is business income, has used the asset for the purposes of its business. On the rate, it held that because the main activity of the assessee was to lease out or give the trucks on hire to others, the assessee fulfils even the requirements for a claim of a higher rate of depreciation and is entitled to it.
Section 32 sets two conditions and the case turns on reading each of them for what it says rather than for what it is assumed to say. The first is ownership. The department's argument was documentary and had a certain force: the registration certificate named the lessee as owner, and the registration certificate is the public record of who owns a vehicle. The Court's answer was that the record is made for a purpose. Section 2(30) of the Motor Vehicles Act brings the person in possession under a lease or hire-purchase agreement within the word 'owner' by a deeming provision, and a deeming provision does the work the statute that contains it needs done - here, fixing who answers for the vehicle on the road. It does not decide who owns the vehicle for the Income-tax Act. Against that, the Court put the lease agreement, which said the assets remain at all times the sole and exclusive property of the lessor and gave the lessor repossession, inspection and return rights. The test it stated is one of title good against the world: as long as the assessee has a right to retain the legal title of the vehicle against the rest of the world, it is the owner in the eyes of law. The Court also looked at the practical side of the same question. Nothing had been brought on record to show that the lessees had claimed depreciation on the vehicles they used, and the Court drew the inference that they had not and that it was the lessor alone who had claimed it as the actual owner. That is a finding about the record, not a rule, and it matters to how far the case can be pushed. The second condition is use. The words are 'used for the purposes of the business'. The department read them as requiring the assessee to put the vehicle to work itself. The Court held that the section does not mandate usage of the asset by the assessee itself; what it requires is that the asset be used for the purposes of the business. Where the business is leasing, and where the income from letting the asset out is assessed as business income, the asset is used for the purposes of that business. The Court took that from its own earlier decisions, including Shaan Finance (P) Ltd, reported at 231 ITR 308, where it had held that if the business of the assessee consists of hiring out machinery, or the income derived from hiring it out is business income, the assessee must be considered as having used the machinery for the purpose of business, and Castle Rock Fisheries, reported at (1997) 10 SCC 77. The rate followed from the same reasoning. The objection below was that the lessor must itself run the vehicles on hire. Once use through the lessee counts as use for the purposes of the lessor's business, and once the main activity of the lessor is leasing out or hiring the vehicles, the higher rate is reached on the same footing as the allowance itself.
As long as the assessee has a right to retain the legal title of the vehicle against the rest of the world, it would be the owner of the vehicle in the eyes of law.
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Handle my notice → Ask a CA on WhatsAppNo. The Supreme Court held that the lessor, not the lessee, is entitled to depreciation on vehicles leased out in the course of a leasing business. Two conditions have to be met under section 32 - ownership and use for the purposes of the business - and the Court held both were satisfied. On ownership, the lease agreement provided that the assets remain at all times the sole and exclusive property of the lessor, and the lessor kept the right to repossess, to inspect and to require the vehicles back; the entry of the lessee as owner in the registration certificate does not displace that, because section 2(30) of the Motor Vehicles Act is a deeming provision creating a fiction of ownership in favour of the lessee only for the purposes of that Act. As long as the assessee has a right to retain the legal title of the vehicle against the rest of the world, it is the owner in the eyes of law. On use, the Court held that section 32 requires the asset to be used for the purposes of business but does not require the assessee to use it himself; leasing was this assessee's business and the lease income was its business income. The Court went further and held the assessee entitled to the higher rate as well, because its main activity was leasing out or hiring the vehicles. The appeals were allowed and the High Court's judgments set aside. This was decided by the Supreme Court (Supreme Court of India - D.K. Jain and Jagdish Singh Khehar JJ) and bears on section 32, section Motor Vehicles Act s.2(30), section 33 (Act of 2025) of the Income Tax Act 1961. It is reported as [2013] 350 ITR 527 (SC). Leasing sits on a fault line between two ways of describing the same transaction. In law the lessor owns the asset and lets it out. In accounting, and in the commercial sense the parties themselves often use, a finance lease is a loan with the asset as security, and the lessee capitalises it. Depreciation follows ownership under section 32, so which description the assessing officer adopts decides who gets the allowance - and on a fleet financed over several years the allowance is the whole economics of the deal. This is the judgment that settles which description the Act uses. Ownership is legal title under the documents, tested by whether the claimant can hold the title against the rest of the world, and it is not displaced by an entry in a register maintained for a different statute's purposes. The second holding is the one that gets less attention and does more work. Section 32 asks whether the asset was used for the purposes of the business, not whether the assessee personally used it. That sentence reaches well past vehicle leasing: it is the answer wherever an assessee owns an asset that someone else physically operates, provided the letting is the assessee's business and the income from it is assessed as business income. Where the case is over-read is on substance. The Court decided on the lease terms before it and on a record that showed nobody else had claimed the depreciation. It is not authority that a transaction can never be looked through, and an officer who produces a lessee's own depreciation claim on the same asset has taken the case outside what was decided. If it applies to you, the first step is this: Put the lease agreement in front of the officer, not the registration certificate. The clause that decides ownership is the one saying the assets remain the sole and exclusive property of the lessor, read with the repossession, inspection and return clauses.
The appellant was a non-banking finance company whose business included leasing. It bought vehicles, including trucks, from the manufacturers and leased them to its customers. The lease agreements provided that the assets would at all times remain the sole and exclusive property of the lessor, and gave the lessor rights of repossession and inspection and a right to have the vehicles returned. Under the Motor Vehicles Act the lessees were entered as the owners in the registration certificates. The company claimed depreciation on the leased vehicles, and claimed it at the higher rate of fifty per cent applicable to motor vehicles used in a business of running them on hire. The Commissioner (Appeals) took the view that the company had only financed the purchase of the trucks, so that leasing or hiring them out did not amount to carrying on the business of hiring trucks, and that the company had to use the trucks in its own business of running them on hire before it could claim the higher rate. The Appellate Tribunal held that the assessee, having used the trucks for the purpose of business, was entitled to depreciation at the higher rate on the trucks leased out by it. The High Court of Karnataka reversed the Tribunal. The company came to the Supreme Court in Civil Appeals Nos. 3282, 3286, 3287, 3288, 3289 and 3290 of 2008. The matter was decided on 2013-01-14 by the Supreme Court (Supreme Court of India - D.K. Jain and Jagdish Singh Khehar JJ). On those facts the Supreme Court held as follows. The High Court erred in law in reversing the Tribunal. In its concluding paragraph the Court said: "For the foregoing reasons, in our opinion, the High Court erred in law in reversing the decision of the Tribunal. Consequently, the appeals are allowed; the impugned judgments are set aside and the substantial questions of law framed by the High Court, extracted in para 7 (supra), are answered in favour of the assessee and against the Revenue. There will, however, be no order as to costs." The questions so answered were whether the assessee is the owner of the vehicles leased out to its customers and whether it is entitled to the higher rate of depreciation on them. On ownership, the Court held that section 2(30) of the Motor Vehicles Act is a deeming provision creating a legal fiction of ownership in favour of the lessee only for the purposes of that Act, and that as long as the assessee has a right to retain the legal title of the vehicle against the rest of the world it is the owner of the vehicle in the eyes of law. On use, it held that section 32 requires the assessee to use the asset for the purposes of business and does not mandate usage of the asset by the assessee itself, so that a lessor whose business is leasing, and whose lease income is business income, has used the asset for the purposes of its business. On the rate, it held that because the main activity of the assessee was to lease out or give the trucks on hire to others, the assessee fulfils even the requirements for a claim of a higher rate of depreciation and is entitled to it.
Section 32 sets two conditions and the case turns on reading each of them for what it says rather than for what it is assumed to say. The first is ownership. The department's argument was documentary and had a certain force: the registration certificate named the lessee as owner, and the registration certificate is the public record of who owns a vehicle. The Court's answer was that the record is made for a purpose. Section 2(30) of the Motor Vehicles Act brings the person in possession under a lease or hire-purchase agreement within the word 'owner' by a deeming provision, and a deeming provision does the work the statute that contains it needs done - here, fixing who answers for the vehicle on the road. It does not decide who owns the vehicle for the Income-tax Act. Against that, the Court put the lease agreement, which said the assets remain at all times the sole and exclusive property of the lessor and gave the lessor repossession, inspection and return rights. The test it stated is one of title good against the world: as long as the assessee has a right to retain the legal title of the vehicle against the rest of the world, it is the owner in the eyes of law. The Court also looked at the practical side of the same question. Nothing had been brought on record to show that the lessees had claimed depreciation on the vehicles they used, and the Court drew the inference that they had not and that it was the lessor alone who had claimed it as the actual owner. That is a finding about the record, not a rule, and it matters to how far the case can be pushed. The second condition is use. The words are 'used for the purposes of the business'. The department read them as requiring the assessee to put the vehicle to work itself. The Court held that the section does not mandate usage of the asset by the assessee itself; what it requires is that the asset be used for the purposes of the business. Where the business is leasing, and where the income from letting the asset out is assessed as business income, the asset is used for the purposes of that business. The Court took that from its own earlier decisions, including Shaan Finance (P) Ltd, reported at 231 ITR 308, where it had held that if the business of the assessee consists of hiring out machinery, or the income derived from hiring it out is business income, the assessee must be considered as having used the machinery for the purpose of business, and Castle Rock Fisheries, reported at (1997) 10 SCC 77. The rate followed from the same reasoning. The objection below was that the lessor must itself run the vehicles on hire. Once use through the lessee counts as use for the purposes of the lessor's business, and once the main activity of the lessor is leasing out or hiring the vehicles, the higher rate is reached on the same footing as the allowance itself. In the words reproduced by the source cited on this page: "As long as the assessee has a right to retain the legal title of the vehicle against the rest of the world, it would be the owner of the vehicle in the eyes of law."
It was decided by the Supreme Court on 2013-01-14 and is reported as [2013] 350 ITR 527 (SC). Binding on every court and authority in India. A Supreme Court decision binds every assessing officer, every Commissioner (Appeals), every bench of the Income Tax Appellate Tribunal and every High Court in India. An officer who declines to follow it is acting contrary to law, and that refusal is itself a ground of appeal. On section 32, section Motor Vehicles Act s.2(30), section 33 (Act of 2025), the practical question is whether the facts of your own notice match the facts of this case closely enough for the same rule to apply.
It helps the taxpayer. The High Court erred in law in reversing the Tribunal. In its concluding paragraph the Court said: "For the foregoing reasons, in our opinion, the High Court erred in law in reversing the decision of the Tribunal. Consequently, the appeals are allowed; the impugned judgments are set aside and the substantial questions of law framed by the High Court, extracted in para 7 (supra), are answered in favour of the assessee and against the Revenue. There will, however, be no order as to costs." The questions so answered were whether the assessee is the owner of the vehicles leased out to its customers and whether it is entitled to the higher rate of depreciation on them. On ownership, the Court held that section 2(30) of the Motor Vehicles Act is a deeming provision creating a legal fiction of ownership in favour of the lessee only for the purposes of that Act, and that as long as the assessee has a right to retain the legal title of the vehicle against the rest of the world it is the owner of the vehicle in the eyes of law. On use, it held that section 32 requires the assessee to use the asset for the purposes of business and does not mandate usage of the asset by the assessee itself, so that a lessor whose business is leasing, and whose lease income is business income, has used the asset for the purposes of its business. On the rate, it held that because the main activity of the assessee was to lease out or give the trucks on hire to others, the assessee fulfils even the requirements for a claim of a higher rate of depreciation and is entitled to it. It arises in Deductions & Disallowances and How Tax Law Is Read matters, on section 32, section Motor Vehicles Act s.2(30), section 33 (Act of 2025) of the Income Tax Act 1961, and was decided by Supreme Court of India - D.K. Jain and Jagdish Singh Khehar JJ. Before relying on it, read the source linked on this page and check whether it has since been distinguished, overruled or overtaken by an amendment to the Income Tax Act. In practice the steps that follow from it are these. Meet the registration point head on. Section 2(30) of the Motor Vehicles Act makes the person in possession under a hire-purchase or lease agreement the owner for that Act; the Supreme Court held that fiction does not travel into section 32. Show that nobody else has claimed the depreciation. The Court recorded that nothing was brought on record to show the lessees had claimed it, and drew an inference from that. If your lessee has claimed and been allowed depreciation on the same vehicle, this judgment does not answer your case. Show the leasing is your business, not an incident of it. The Court's answer on use turns on leasing being the assessee's business and the lease income being assessed as business income; get the assessment of that income right first. If you want the higher rate, establish that the main activity is giving the vehicles out on hire. The officer's objection here was that the lessor must itself run the vehicles on hire, and the Court rejected it. Keep the lease documents, the purchase invoices from the manufacturers and the delivery records together. Ownership was established on documents, and the case is only as good as yours.
Still good law. The case is applied as a matter of course and has not been doubted. The Rajasthan High Court applied it within months, in Commissioner of Income Tax v Baid Leasing and Finance Co Ltd on 1 July 2013, setting the concluding paragraph out in full and citing the case at (2013) 3 SCC 541. The Tribunal at Ahmedabad worked through it in Gujarat Lease Financing Ltd, pronounced 28 February 2014, citing it at 350 ITR 527 and holding on its authority that the lessor is the owner of the vehicles and, as the owner, used the assets. Benches at Kolkata, Mumbai, Bangalore, Delhi and Amritsar have followed it since, and it is the decision cited whenever an officer treats a lease as a disguised loan and moves the depreciation to the lessee. The limits deserve attention because the case is quoted well beyond them. The Court decided this on the terms of the lease agreement and on the absence of any material showing that the lessees had claimed depreciation. It did not lay down that the character of a transaction can never be examined, and it did not hold that a financier who has in substance lent money and taken the asset only as security is entitled to depreciation. A case where the lessee has claimed and been allowed depreciation on the same asset is a different case from this one, and the inference the Court drew from the record here would not be available. The accounting has moved on around the judgment without displacing it. A finance lease is capitalised in the lessee's books under the accounting standards, and the Income Computation and Disclosure Standards notified under section 145(2) do not alter who owns an asset for section 32. Ownership under section 32 remains a question of legal title under the documents, which is what this judgment decides. The Income-tax Act, 1961 was repealed on 1 April 2026 by section 536(1) of the Income-tax Act, 2025, and section 536(2)(c) continues it for proceedings about tax years beginning before that date. Depreciation is now dealt with by section 33 of the 2025 Act. The two conditions this judgment construes - ownership and use for the purposes of the business - are the conditions the allowance has always carried, and the reasoning about a deeming provision in another statute, and about use through a lessee, does not depend on the numbering. No source could be cited for that finding. Checking whether an authority still stands matters as much as knowing what it held: a decision may be overruled on one point and survive on another, or the provision it interprets may have been amended since. Read the source and the editor's note on this page before relying on it in a reply to an Assessing Officer or in an appeal.
This record was built from the judgment's own text, and the operative order and the two sentences that carry the reasoning were each checked before being used. The judgment was read on its own page in printed form. It runs to thirty-two numbered paragraphs, and every passage relied on here was located in that text and read in the paragraphs around it rather than taken from any summary of the case. The concluding paragraph was read twice on the judgment's own page, ending with the signatures of D.K. Jain J and Jagdish Singh Khehar J and the date, New Delhi, January 14, 2013. The operative paragraph was then found in another court. The Rajasthan High Court set it out in full on 1 July 2013 in Commissioner of Income Tax v Baid Leasing and Finance Co Ltd, citing the case at (2013) 3 SCC 541, and its reproduction matches the text on this page word for word. It numbers that paragraph 34 and its internal reference to the questions of law as paragraph 8, where the copy read numbers them 32 and 7, so the words are corroborated and the numbering is not; no bare paragraph number is relied on here. The same High Court also carries the sentence that section 32 does not mandate usage of the asset by the assessee itself. The substance was checked against another forum as well. The Tribunal at Ahmedabad in Gujarat Lease Financing Ltd, pronounced 28 February 2014, cites the case at 350 ITR 527 and applies it in terms, holding that the lessor is the owner of the vehicles and that as the owner it used the assets. The Tribunal at Kolkata in EIH Limited, decided 19 February 2016, carries the proposition that the fact that the trucks themselves were not used by the assessee was irrelevant for the purpose of the section. The earlier authorities the Court applied were checked as printed in the judgment and are named here as it names them, with the citation strings it prints: Shaan Finance (P) Ltd at 231 ITR 308 and Castle Rock Fisheries at (1997) 10 SCC 77. No account of either is given on this page beyond the sentence the Supreme Court itself took from them. One caution for anyone citing it. The case is filed on the taxpayer's side and belongs there, but it is marked as a trap because of how often it is quoted for more than it decides. It decides ownership on the terms of these lease agreements and on a record in which no lessee had claimed the allowance. It is not a rule that a financing arrangement can never be examined for what it is. The assessment years are not stated in the copy read, and neither are the amounts of depreciation in dispute or the dates of the orders below; the appeals are identified by their numbers alone. The date and number of the High Court's judgment are not given. The judgment refers to the substantial questions of law framed by the High Court and extracted at its paragraph 7, and the copy read gives the substance of those questions - whether the appellant is the owner of the vehicles leased out to its customers and whether it is entitled to the higher rate of depreciation - but not the full formal wording of each. The paragraph numbers differ between reports: the copy read numbers the concluding paragraph 32 and its internal reference to the questions as paragraph 7, while the report the Rajasthan High Court follows numbers them 34 and 8. Cite the passage by its words rather than by a number, or check the number in the report you are using. The Court decided ownership and use. It did not decide how the lease rentals themselves are to be taxed, and it did not decide anything about the lessee's position: whether a lessee who has capitalised the asset in its books can claim any allowance, and what happens if lessor and lessee both claim, are questions this judgment leaves open. It records that nothing was brought on record to show the lessees had claimed depreciation, which is a finding about this record rather than a holding. The judgment does not address the Income Computation and Disclosure Standards or the accounting standards on leases, which came later or were not in issue, and nothing here should be read as deciding how a finance lease is to be recognised in the accounts. It also does not deal with hire-purchase as distinct from lease, although section 2(30) of the Motor Vehicles Act covers both, so a hire-purchase agreement with an option to purchase raises a question of ownership this case does not answer. The rate of fifty per cent is the rate that was in the depreciation schedule for the years in dispute. Rates have changed since, and the holding is that the higher rate applies on these facts, not that any particular percentage does. This library shows the verification state of every entry openly. This entry has not yet been read in full by a chartered accountant. The summary reflects the sources listed on this page. Read the source before you rely on it in a reply to an Assessing Officer or in an appeal before the Commissioner (Appeals) or the Income Tax Appellate Tribunal.
The High Court erred in law in reversing the Tribunal. In its concluding paragraph the Court said: "For the foregoing reasons, in our opinion, the High Court erred in law in reversing the decision of the Tribunal. Consequently, the appeals are allowed; the impugned judgments are set aside and the substantial questions of law framed by the High Court, extracted in para 7 (supra), are answered in favour of the assessee and against the Revenue. There will, however, be no order as to costs." The questions so answered were whether the assessee is the owner of the vehicles leased out to its customers and whether it is entitled to the higher rate of depreciation on them. On ownership, the Court held that section 2(30) of the Motor Vehicles Act is a deeming provision creating a legal fiction of ownership in favour of the lessee only for the purposes of that Act, and that as long as the assessee has a right to retain the legal title of the vehicle against the rest of the world it is the owner of the vehicle in the eyes of law. On use, it held that section 32 requires the assessee to use the asset for the purposes of business and does not mandate usage of the asset by the assessee itself, so that a lessor whose business is leasing, and whose lease income is business income, has used the asset for the purposes of its business. On the rate, it held that because the main activity of the assessee was to lease out or give the trucks on hire to others, the assessee fulfils even the requirements for a claim of a higher rate of depreciation and is entitled to it.
TaxSphere, “I.C.D.S. Ltd v CIT”, https://taxnotice.vittsphere.com/caselaw/case/icds-ltd-v-cit-lessor-not-lessee-gets-depreciation-on-a-leased-vehicle/ (validity last checked 2026-09-23)
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I demolished my landlord's building and put up a new one at my own cost, and the new building belongs to him. I got a 39-year lease at a fraction of the market rent for it. Is what I spent capital or revenue?
I wrote off the whole cost of a laboratory building and its equipment under the scientific research provision. Can I also take depreciation on the same assets in later years, and can the department deny it for years before 1980 using an amendment made in 1980?
I borrowed to buy and install my plant and paid interest before production started — can I add that interest to the cost of the plant and claim depreciation on it?
I built a cinema and capitalised the land with the building. Can I claim depreciation on the whole cost, or must the land be taken out?
