VIACOM 18, MEDIA PVT LTD ,MUMBAI vs. PCIT-8, MUMBAI

ITA 2591/MUM/2025Status: DisposedITAT Mumbai27 November 2025AY 2019-2033 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the PCIT was not justified in disturbing the plausible view adopted by the Assessing Officer regarding depreciation on goodwill. It also found no infirmity in the Assessing Officer's allowance of carry forward of losses.

What were the facts?

The assessee claimed depreciation on goodwill and carry forward of losses. The PCIT initiated revision proceedings under Section 263, holding the assessment order to be erroneous and prejudicial to the revenue. The assessee appealed this order.

What were the issues?

Whether the PCIT was justified in invoking Section 263 when the Assessing Officer had taken a plausible view on depreciation on goodwill and carry forward of losses. Whether depreciation on goodwill arising from amalgamation is allowable.

Which sections of the Income-tax Act were involved?

Section 263,Section 32,Section 143(3),Section 144B

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Income Tax Appellate Tribunal, MUMBAI BENCH “F” MUMBAI

Before: SHRI OM PRAKASH KANT & SHRI RAJ KUMAR CHAUHAN

For Appellant: Mr. Madhur Agarwal/Ms. Moksha
For Respondent: Mr. Vivek Perampurna, CIT-DR
Pronounced: 15/09/2025

PER OM PRAKASH KANT, AM This appeal by the assessee is directed against revisional order dated 18/03/2025 passed by the learned Principal Commissioner of Income-tax, Mumbai-8 [in short 'the learned PCIT'] under section 263 of Income-tax Act, 1961 (in short 'the Act') wherein he set aside the assessment order passed by the faceless assessment unit (in short 'the Assessing Officer') holding it to be erroneous insofar as prejudicial to the interest of the Revenue. The grounds raised by the assessee in its appeal are reproduced as under:

On the facts and in the circumstances of the case and in law, th

The order continues below.

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