Judgment :- Arijit Pasayat, CJ. In the present reference under S.256(1) of the Income Tax Act, 1961 (in short 'the Act'), an interesting question arises for consideration. Question, as referred to by Income Tax Appellate Tribunal, Cochin Bench (in short 'Tribunal'), reads as follows: "Whether on the facts and in the circumstances of the case, the Tribunal was right in law and fact in holding that the assessing officer was not obliged to grant depreciation when the assessee did not furnish the requisite particulars and it was the intention of the assessee not to claim depreciation?" There appears to be divergence of views so far as various High Courts are concerned on the question. Since it does not require elaborate reference to factual aspects, we straightaway proceed to deal with the question on the legal aspects; noticing factual aspects briefly. 2. Assessment year involved is 1986-87. Assessee filed its return of income on 30.9.1986, but did not claim any depreciation. Assessee informed assessing officer that it was not claiming depreciation for the concerned assessment year and, therefore, proscribed particulars for claiming such depreciation were not being filed. Inspite of this, assessing authority, suo mote, allowed depreciation by its order dated 10.11.1988. Assessee carried the matter in appeal before the commissioner of Income Tax (Appeals) (In short'CIT (A)'). Said appellate authority held that assessing officer was not obliged to grant depreciation when assessee did not furnish particulars. Said order was assailed before Tribunal by the Revenue. Conclusions of CIT (A) were affirmed by Tribunal. 3. Learned counsel for Revenue submitted that it was not necessary for assessing authority to rely on particulars and if they were self contained, deduction for depreciation could be granted even if assessee had not claimed it. Learned counsel for assessee, on the other hand, contended that the condition precedent for grant of deduction is "claim" and "furnishing of particulars". If assessee did not want to get deduction, it was not open to assessing officer to grant it. 4. Before we deal with rival submissions, it is necessary to take note of the views expressed by different High Courts. While the Andhra Pradesh (see: C.I.T. v. Andhra Cotton Mills Ltd. - 228 ITR 30, Bombay (see: C.I.T. v. Shri Someshwar Sahakari Sakhar Karkhana Ltd. -177 ITR 443). 4. Before we deal with rival submissions, it is necessary to take note of the views expressed by different High Courts. While the Andhra Pradesh (see: C.I.T. v. Andhra Cotton Mills Ltd. - 228 ITR 30, Bombay (see: C.I.T. v. Shri Someshwar Sahakari Sakhar Karkhana Ltd. -177 ITR 443). Gujarat (see: C.I.T. v. Arun Textile ' C -192 ITR 700), Karnataka (see: Chief C.I. T. (Admn) v. Machine Tool Corporation of India Ltd-201 ITR 101) and Punjab and Haryana (see: Beco Engineering Co. Ltd. v. C.I.T., Rohtak -148 ITR 478) High Courts have taken the view which assists the assessee, the Allahabad (see: Ascharaylal Ram Prakash v. C.I.T., UP- 90 ITR 477) and Madras (see: C.I. T. v. Southern Petrochemical Industries Corporation Ltd. (No, 2) -233 ITR 400) High Courts have taken a different view. 5. Provision dealing with grant of deduction for depreciation is S.34 of the Act. Corresponding provision in the 1922 act is s. 10(2)(vi). Sub-s.(1) of S.10 of the Indian Income Tax Act, 1922 deals with the tax payable by an assessee in respect of profits or gains of any business, profession or vocation carried on by him. Sub-s.(2) requires such profits or gains to be computed after making the allowances therein set out. Clause (vi) thereof speaks of allowances in respect of depreciation of buildings, machinery, plant etc., and the proviso to clause (vi) reads thus: "Provided that - the prescribed particulars have been duly furnished". In the 1961 Act, S.28 deals with the profits and gains of business or profession. Under the provisions of S.29, such income is required to be computed in accordance with the provisions contained in Ss.30 to 43A. S.32 provides for depreciation. In the 1961 Act, S.28 deals with the profits and gains of business or profession. Under the provisions of S.29, such income is required to be computed in accordance with the provisions contained in Ss.30 to 43A. S.32 provides for depreciation. The opening words of sub-s (1) of S.32 read thus: "In respect of depreciation of buildings, machinery, plant or furniture owned by the assessee and used for the purposes of the business or profession, the following deductions shall, subject to the provisions of S.34, be allowed " Sub-s.(1) of S.34 reads thus: "(1) The deductions referred to in sub-s.(1) or sub-s.(1 A) of S.32 shall be allowed only if the prescribed particulars have been furnished; and the deduction referred to in S.33 shall be allowed only if the particulars prescribed for the purpose of clause (i) and clause (ii) of sub-s.(1) of S.32 have been furnished by the assessee in respect of the ship or machinery or plant." It is the construction of S.10(2)(vi) and its proviso under the 1922 Act and of S.34(1) of the 1961 Act which are relevant for the purpose of deciding the first issue. It will be noted that the provisions speak of "allowance" and "allowed". The proviso to clause (vi) of sub-s.(2) of S.10 of the 1922 Act obliges the assessing authority to make an allowance for depreciation as therein stated "Provided that - the prescribed particulars have been duly furnished." Sub-s.(1) of S.34 of the 1961 Act obliges the Income Tax Officer to allow the deductions referred to in S.32 "only if the prescribed particulars have been furnished". The provisions of the 1922 and 1961 Acts are, therefore, pan materia in this regard. 6. The word "allow" is defined by the Shorter Oxford English Dictionary (Third Edition) to mean, inter alia, "to accept as satisfactory", "to accept as true or valid", "to admit", "to concede, permit". The word "allowance" is defined as, inter alia, "the action of allowing; a thing allowed". The use of the words "allowed" and "allowance" in the provisions would appear to contemplate a claim or application by the assessee for the deduction therein provided for. The claim or application could be allowed and the allowance given thereon. In the absence of a claim or application by assessee, the assessing authorities would not be "allowing" a deduction. The use of the words "allowed" and "allowance" in the provisions would appear to contemplate a claim or application by the assessee for the deduction therein provided for. The claim or application could be allowed and the allowance given thereon. In the absence of a claim or application by assessee, the assessing authorities would not be "allowing" a deduction. The provisions, therefore, suggest that the assessee has the choice of seeking or not seeking the allowance of the deduction. This is all the more so because the provisions state explicitly that depreciation can be allowed provided or only if the prescribed particulars have been furnished. The words in this behalf in the provisions cannot be wished away and it is no answer to say, as counsel for Revenue did, that S.10(1) of the 1922 Act and S.29 of the 1961 Act oblige the Income Tax Officer to compute an assessee's business income in accordance with the provisions contained therein and thereafter respectively. These words occur in the provisions of S.10 of the 1922 Act and S.34 of the 1961 Act and must be given a meaning. For the purpose of computing an assessee's business income under S.10 of the 1922 Act and S.34 of the 1961 Act, the Income Tax Officer can allow the deduction by way of depreciation provided and only if the prescribed particulars in this regard have been furnished to him, that is to say, given to him. Ordinarily, the particulars would be available only to the assessee and only the assessee can furnish or give them to the Income Tax Officer. Further, the only prescription of the particulars is in the proforma of the return, so that the furnishing or giving thereof would only be by the return filled in by assessee. If the Legislature had intended that the Income Tax Officer should give a deduction for depreciation whether or not the assessee wanted it, it would not have used such language in the provisions as enabled the assessee to frustrate the intention by simple expedient of not furnishing prescribed particulars. The provisions, therefore, prescribe two preconditions to the allowance of a deduction for depreciation. The first, which is implicit, is that the assessee should have asked for it. The second, which is explicit, is that prescribed particulars should have been furnished. The provisions, therefore, prescribe two preconditions to the allowance of a deduction for depreciation. The first, which is implicit, is that the assessee should have asked for it. The second, which is explicit, is that prescribed particulars should have been furnished. If either of these conditions is not fulfilled, the deduction cannot be allowed by Income Tax Officer. This position has been elaborately dealt with by Bombay High Court in C.I.T. v. Shri Someshwar Sahakari Sakhar Karkhana ((1989) 7. S.34(1) made depreciation allowable "only if the prescribed particulars have been furnished". The requisite particulars were, up to assessment year 1980-81, made a part of the form of return itself. For assessment years 1981-82 to 1987-88, such particulars were detailed in Rule 5AA of the Income Tax Rules, 1962 (in short'the rules'), which was inserted by the Income Tax (First Amendment) Rules, 1981 with effect from 1st April 1981. Unless such particulars were given, duly filled in the return form for the assessment years up to 1980-81, and in a columnar form as per Rule 5AA for assessment years 1981-82 to 1987-88, depreciation even if claimed could not have been allowed. Position would certainly not be different when assessee had not either claimed it or not furnished the requisite particulars. The word "allow" means "to reckon as a deduction", "to remit, concede". There cannot be a concession or concession suo motu unless statutorily provided for. It is a well settled salutary principle that if a statute provides for a thing to be done in a particular manner, then it has to be done in that manner and in no other manner, (see: Nazir Ahamed v. King Emperor - AIR 1936 PC 253; Rao Shiv Bahadur Singh & Ann v. State of Vindhya Pradesh - AIR 1954 SC 322; State of Uttar Pradesh v. Singhara Singh & Ors. - AIR 1964 SC 358 and Chandra Kishore Jha v. Mahavir Prasad & Ors. - JT 1999 (7) SC 256). 8. Depreciation is, as indicated above, is a benefit available to assessee. But in case assessee chooses not to claim it, it would be contrary to reason and law to hold that it must be imposed upon him. - AIR 1964 SC 358 and Chandra Kishore Jha v. Mahavir Prasad & Ors. - JT 1999 (7) SC 256). 8. Depreciation is, as indicated above, is a benefit available to assessee. But in case assessee chooses not to claim it, it would be contrary to reason and law to hold that it must be imposed upon him. It is also necessary to take note of the circular issued by Central Board of Revenue (No. 29D (XIX-14) of 1965, F. No 45/239/65-ITJ dated August 31,1965) which directed that "where the required particulars have not been furnished by the assessee and no claim for depreciation has been made in the return, the Income Tax Officer should estimate the income without allowing depreciation allowance". Further circular of the Central Board of Revenue (No. 14 (XL-35) of 1955 dated April 11, 1955) required officers of the Department to "assist a tax payer in every reasonable way, particularly in the matter of claiming and securing reliefs although, therefore, the responsibility for claiming refunds and reliefs rests with assessees on whom it is imposed by law, officers should - (a) draw their attention to any refunds or reliefs to which they appear to be clearly entitled but which they have omitted to claim for some reason or other " A claim, therefore, had to be made by assessee for a relief to which he was entitled and that the Income Tax Officer's duty was only to advise him of it. We are in agreement with the view expressed which supports assessee's stand. Contrary view appears to have been arrived at with the logic that true income of an assessee is to be arrived at and even if it has not been claimed, it is open to the Income Tax Officer to grant depreciation if particulars are available notwithstanding non-claim or withdrawal by assessee in the revised return. Most of the cases taking said view related to cases where original returns were filed claiming deduction and giving particulars and subsequently withdrawal of claim was made in the revised returns. With great respect, we find ourselves unable to subscribe to that view. Factually also, the position is different in this case. However, that would not make any difference so far as our conclusions are concerned. In the aforesaid premises, our answer to the question is in the affirmative in favour of assessee, and against Revenue.