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Microlesson · 5-min read

Depreciation — Conditions & Eligibility [Section 32]

## Depreciation [Section 32] — Conditions for Allowance

### Depreciation is a COMPULSORY deduction

Per Explanation 5 to Section 32, depreciation is mandatory — it is allowed even if the assessee does not claim it.

### Three conditions [Rule 5]

(a) Asset must fall in an eligible category

  • Tangible: Buildings, furniture, and Plant & Machinery (residuary).
  • Intangible: Know-how, patents, copyrights, trademarks, licences, franchises and similar commercial rights acquired on or after 1 April 1998.
  • No depreciation on the cost of Land and on Goodwill.
  • Depreciation is allowed on parts/components (e.g., engine of a vehicle, part of machinery/building).
  • Meaning of 'Plant':
  • Includes: ships, books, vehicles, scientific apparatus, surgical equipment used for business.
  • Excludes: tea bushes, livestock, buildings, furniture, fittings, animals, human bodies, stock-in-trade.
  • 'Buildings' includes roads, bridges, culverts, wells and tubewells.

(b) Asset must be USED for business during the PY

  • Must be put to use at any time during the year; passive usage (kept ready for use — e.g., standby equipment, fire extinguishers) qualifies.
  • 50% rule: If an asset is acquired AND put to use for < 180 days in the first year, only 50% of the prescribed rate is allowed that year. Applies only in the year of acquisition, not later years.
  • An assessee in the leasing business can claim depreciation even though the asset is used by the lessee.
  • If not used exclusively for business, only proportionate depreciation is allowed [Sec. 38(2)].

(c) Assessee must OWN the asset (wholly or partly)

  • Ownership (whole or part) is required.
  • The assessee need not own the land on which he constructs a building.
  • If the assessee incurs capital expenditure on a leased building (construction/renovation/improvement), depreciation is allowed on that capital expenditure.

Worked example

### Example 1

Half-rate first year: A machine (15% block) costing ₹10,00,000 is acquired and put to use on 1 Feb (used < 180 days in the first year). → Depreciation = 50% × 15% × ₹10,00,000 = ₹75,000 in year 1.

### Example 2

Capital expenditure on leased building: An assessee constructs a structure costing ₹20,00,000 on land taken on lease. → Although he does not own the land, depreciation is allowed on the ₹20,00,000 capital expenditure (building block).

⚠️ Common exam mistakes

  • Claiming depreciation on land or goodwill — both are excluded.
  • Forgetting that depreciation is compulsory (Explanation 5) — WDV must be reduced even if not claimed.
  • Applying the 50% (half-rate) rule in years after the year of acquisition — it applies only in the first year.
  • Denying a lessor depreciation because the lessee uses the asset — the owner-lessor can still claim it.
  • Treating intangibles acquired before 1 April 1998 as eligible, or ignoring the proportionate restriction (Sec. 38(2)) for non-exclusive business use.
Bare-Act text Section 32; Rule 5; Sec. 38(2) · Income-tax Act, 1961 · click to expand
Explanation 5 to Section 32: For the removal of doubts, it is hereby declared that the provisions of this sub-section shall apply whether or not the assessee has claimed the deduction in respect of depreciation in computing his total income.
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