Questione giuridica chiave
Whether extraordinary depreciation on the factory building and fixed assets was tax-deductible for 2002-2003.
Decisione estratta
The challenged tax add-backs for extraordinary depreciation were justified and remain upheld.
Motivazione estratta
The taxpayer did not prove an exceptional loss in value of the building or equipment. Ordinary tax depreciation rates were already generous, the neighboring plant was built only in 2004, and the alleged nuisances did not show a concrete depreciation of those assets in 2002-2003.