The AO analysed depreciation claimed on plant and machinery, including amounts attributed to foreign exchange fluctuation liability under Section 43A. On behalf of the assessee, it was argued that the reopening was based solely on material already on record during the original scrutiny assessment and that there was no fresh tangible material. It is evident from these two tables that assessee has claimed depreciation of Rs.2991,11,66,989/- on this class of assets as under:(1) Depreciation @ 15% on Rs. 49,60,75,409/-Total depreciation claimed Rs.2991 41,66,989 (2700,22,20,657 37,20,56,556 + 204,38,14,367 +49,60,75,409)Note. It was submitted that in absence of fresh tangible material after the scrutiny assessment is over, reopening in such circumstances is not permissible.