DY. COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PUNE, PUNE vs. CAPGEMINI TECHNOLOGY SERVICES INDIA LIMITED(PREVIOUS KNOWN AS ARICENT TECHNOLOGIES HOLDINGS) LTD.), PUNE

ITA 2043/PUN/2025Status: DisposedITAT Pune13 August 2026AY 2018-1920 pages
AI SummaryDismissed

What were the facts?

The Revenue appealed against the CIT(A)'s order deleting additions made by the Assessing Officer on account of depreciation on goodwill and ESOP expenses. The assessee had claimed depreciation on goodwill and deducted ESOP expenses, which the AO disallowed.

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision to delete both additions. It relied on previous consistent decisions of the Tribunal in the assessee's own case for similar issues regarding depreciation on goodwill and ESOP expenses.

What were the issues?

Whether depreciation on goodwill is allowable and whether ESOP expenses are deductible business expenditures.

Which sections of the Income-tax Act were involved?

Section 32,Section 37(1),Section 40(a)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE

Before: SHRI R. K. PANDA & Ms. ASTHA CHANDRA

For Appellant: Shri Nikhil S Pathak
For Respondent: Shri Vishwas S. Mundhe, CIT

PER R.K. PANDA, VP:

This appeal filed by the Revenue is directed against the order dated 10.06.2025 of the Ld. CIT(A) / NFAC relating to assessment year 2018-19. 2. Facts of the case, in brief, are that the assessee is a company engaged in the business of developing packaged software, software consulting services and other ancillary products and serves primarily for the use of the telecommunication industry. It filed its return of income on 30.11.2018 declaring total income of Rs.3,97,63,16,740/-. The case was selected for scrutiny under CASS criteria for complete scrutiny. Accordingly, statutory

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 32

All 2,691 judgments and leading authorities on Section 32 →

Recent GST High Court judgments

Search GST case law →