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Microlesson · 5-min read

Actual Cost [Section 43(1)] and Special Situations

# Actual Cost [Section 43(1)]

The actual cost of an asset is the base on which depreciation is computed. Section 43(1) defines it and the Explanations to it deal with special situations.

## Core rule

  • Actual cost = the actual cost of the asset to the assessee (purchase price + expenses to bring it to working condition).
  • Cash payment disallowance: If any payment exceeding ₹10,000 in a single day for acquiring the asset is made otherwise than by approved modes, that part of the cost is treated as NIL (no depreciation on it).
  • Approved modes: Account-payee cheque, account-payee bank draft, or electronic clearing systems — UPI / IMPS / NEFT / RTGS / BHIM / Aadhaar Pay.

## Actual cost in special situations (Explanations to Sec. 43(1))

Expl.SituationAmount added to the block
1Asset used for business/profession after it ceases to be used for scientific researchActual cost minus deduction allowed u/s 35 (often NIL)
1AConversion of inventory (stock-in-trade) into capital assetFMV on date of conversion
2Asset acquired by gift or inheritanceActual cost to previous owner minus notional depreciation + installation & freight incurred
3Second-hand asset where AO feels purpose is to avoid taxCost determined by AO with prior approval of JCIT
4Asset used for B/P, sold, and reacquired by the assesseeLower of: (a) original actual cost minus notional depreciation till date of sale, OR (b) actual reacquisition price
4ASecond-hand asset given on lease/hire to the previous owner (overrides Expl. 3)WDV to the previous owner at the time of acquisition from him
5Personal building brought into B/P use; other personal assets brought into B/PActual cost minus notional depreciation
8Interest on loan borrowed to acquire an assetInterest up to the date the asset is first put to use is capitalised
9Refundable taxes under customs and GST lawShall NOT be included in actual cost
10Subsidies/grants — a portion of cost met by another person (CG/SG/any other)That portion is excluded from cost
11Asset bought outside India by a non-resident, then brought into India for B/PActual cost minus notional depreciation
13Asset used for specified business (35AD) by assessee/previous owner and brought into normal B/PActual cost minus 35AD deduction = NIL; (proviso, where 35AD(7B) applies → actual cost minus notional depreciation)

## Key principles to remember

1. Notional depreciation = depreciation that would have been allowed (whether or not actually claimed). It is deducted in Explanations 2, 4, 5, 11, and the proviso to 13 — the law assumes the asset has aged.

2. No double benefit: Where a deduction was already taken under another section (Sec. 35 for research, Sec. 35AD for specified business), the asset enters the block at NIL — depreciation cannot be claimed again (Explanations 1 and 13).

3. Refundable taxes (GST/customs) and subsidies reduce/exclude from cost — you cannot depreciate amounts you recover or did not bear.

Worked example

### Example 1

Cash payment disallowance: A trader buys machinery for ₹50,000 and pays ₹15,000 of it in cash (single day) and ₹35,000 by account-payee cheque. The ₹15,000 cash payment exceeds ₹10,000 and is not by an approved mode → that ₹15,000 is treated as NIL cost. Actual cost eligible for depreciation = ₹35,000.

### Example 2

Explanation 2 (gift): Mr. A receives machinery by gift from his father, who had bought it for ₹1,00,000 and on which notional depreciation of ₹40,000 would have been allowed. Mr. A pays ₹5,000 freight to bring it to his factory. Actual cost to Mr. A = ₹1,00,000 − ₹40,000 + ₹5,000 = ₹65,000.

### Example 3

Explanation 10 (subsidy): A unit buys plant for ₹10,00,000; the State Government bears ₹3,00,000 of the cost via a grant. Actual cost for depreciation = ₹10,00,000 − ₹3,00,000 = ₹7,00,000.

⚠️ Common exam mistakes

  • Including refundable GST/customs (input tax credit) in actual cost — refundable taxes must be excluded.
  • Forgetting to deduct notional depreciation in gift/inheritance (Expl. 2) and personal-to-business conversion (Expl. 5) cases — using the previous owner's full original cost is wrong.
  • Capitalising interest beyond the date the asset is first put to use — Explanation 8 caps it at the 'put to use' date; interest after that is a revenue deduction u/s 36(1)(iii).
  • Treating an asset previously used for scientific research (Sec. 35) or specified business (Sec. 35AD) as entering the block at cost — it enters at NIL to prevent double deduction.
Reference: Section 43(1)
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