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Microlesson · 5-min read

Carry Forward and Set-off of Unabsorbed Depreciation [Section 32(2)]

# Carry Forward and Set-off of Depreciation [Section 32(2)]

Depreciation is a statutory allowance. When the business does not have enough profit to absorb it, the excess becomes unabsorbed depreciation.

## Treatment of unabsorbed depreciation

  • When current-year profits are insufficient to fully set off the depreciation allowance, the unabsorbed depreciation is carried forward to the next year.
  • In the next year it is added to (merges with) that year's depreciation allowance and effectively becomes part of it.
  • Unabsorbed depreciation can be carried forward indefinitely (no time limit) until fully set off.

> Because it merges into the next year's depreciation, unabsorbed depreciation enjoys the most generous carry-forward treatment of all losses/allowances.

## Unabsorbed additional depreciation under the default regime [Sec. 115BAC]

If there is unabsorbed additional depreciation under Section 32(1)(iia) from earlier years still outstanding, and the assessee is taxed under the default regime u/s 115BAC:

  • It cannot be set off against current-year income.
  • Instead, the WDV of the block at the beginning of the current year is increased by the amount of unabsorbed additional depreciation not allowed for set-off (so the benefit is recovered prospectively through normal depreciation).

## Order of set-off

Per the Supreme Court in CIT v. Mother India Refrigeration (P.) Ltd.:

1. Current-year depreciation is set off first against business income;

2. then brought-forward business losses;

3. then unabsorbed depreciation of earlier years.

> Detailed sequencing is covered under the chapter on Set-off and Carry-forward of Losses.

Worked example

### Example 1

Indefinite carry forward: A business has current-year depreciation of ₹8 lakh but business profit (before depreciation) of only ₹5 lakh. ₹5 lakh is absorbed; the unabsorbed ₹3 lakh is carried forward and added to next year's depreciation allowance, with no limit on the number of years it may be carried.

### Example 2

Additional depreciation under 115BAC: An assessee opting for the default regime has ₹2 lakh of unabsorbed additional depreciation from an earlier year. It cannot be set off; instead the opening WDV of the relevant block is increased by ₹2 lakh, so it is recovered through future normal depreciation.

⚠️ Common exam mistakes

  • Applying a time limit to unabsorbed depreciation — unlike business losses (8 years), unabsorbed depreciation is carried forward indefinitely.
  • Setting off brought-forward business losses before current-year depreciation — the correct order is current-year depreciation first (Mother India Refrigeration).
  • Trying to set off unabsorbed additional depreciation under the 115BAC default regime — it is instead added to the opening WDV of the block.
Reference: Section 32(2)
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