ACIT - 14(2) (2), MUMBAI vs. PFIZER LTD, MUMBAI

ITA 2108/MUM/2018Status: DisposedITAT Mumbai22 September 2023AY 2014-1583 pages
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What did the Tribunal hold?

The tribunal set aside the issue of depreciation on goodwill to the AO for re-examination of the actual cost. The claim for deduction under Section 35DD for amalgamation expenses was dismissed due to lack of supporting evidence for a portion of the expenditure. The AO's appeal was also partly allowed.

What were the facts?

The assessee company, Pfizer Limited, filed appeals against the CIT(A)'s order for AY 2014-15. The appeals dealt with additions for unreconciled transactions, depreciation on goodwill, and deduction for amalgamation expenses. The AO also filed an appeal regarding disallowance of certain expenses.

What were the issues?

Whether depreciation is allowable on goodwill arising from amalgamation and whether deduction under Section 35DD is admissible for amalgamation expenses without proper substantiation.

Which sections of the Income-tax Act were involved?

Section 32,Section 35DD,Section 37(1),Section 43(1)

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Income Tax Appellate Tribunal, “I” BENCH, MUMBAI

Before: SHRI PRASHANT MAHARISHI, AM & SHRI RAHUL CHAUDHARY, JM

For Appellant: Shri P.J. Pardiwala Sr. Advocate, Shri Jeet Kamdar, Advocate
For Respondent: Shri Ajay Kumar Sharma, CIT
Hearing: 24.08.2023Pronounced: 22.09.2023

Heard together (2 matters)

CO No. 110/Mum/2019
ITA No. 2108/Mum/018

Read from the judgment's own cause title. This page is filed under one of them.

PER PRASHANT MAHARISHI, AM:

01.

These are the cross appeals for assessment year 2014 – 15 filed by the assessee and the learned Assessing Officer as well as one [1] cross objection filed by the assessee for the same assessment year against the appellate order passed by The Commissioner Of Income Tax (Appeals) – 22,

The order continues below.

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