What did the Tribunal hold?

The Tribunal held that since the facts and issues for the current assessment year were identical to the preceding year, and the issue had already been decided in favor of the assessee, the CIT(A) was correct in following the previous decision.

The Revenue appealed the deletion of an addition made by the AO on account of disallowance of depreciation on goodwill. The assessee argued that the issue was decided in their favor for the preceding assessment year by a co-ordinate bench of the Tribunal.

What were the issues?

Whether depreciation on goodwill, artificially created through revaluation, is allowable. Whether a co-ordinate bench's decision for a preceding year on identical facts binds the Tribunal for the current year.

DCIT vs Sagarlaxmi Agriseeds Private… | ITAT Ahmedabad 2026

Income Tax Appellate Tribunal, “A” BENCH, AHMEDABAD

Before: SHRI SANJAY GARG & SHRI NARENDRA PRASAD SINHA

For Appellant: Shri Deepak R Shah, A.R

For Respondent: Shri Kalpesh Rupavatiya, Sr. DR

Hearing: 18/06/2026Pronounced: 19/06/2026

IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH, AHMEDABAD

BEFORE: SHRI SANJAY GARG, JUDICIAL MEMBER AND SHRI NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER आयकर अपील सं./I.T.A. No. 1530/Ahd/2026 (िनधा�रण वष� / Assessment Year : 2018-19) DCIT बनाम Sagarlaxmi Agriseeds / Circle-4(1)(1), Ahmedabad Private Limited Vs. 206, Ashwamegh Avenue, Opp. Mithakhali Garden, Navrangpura, Ahmedabad, Gujarat - 380009 �थायी लेखा सं./जीआइआर सं./PAN/GIR No. : AAWCS7561F (Appellant) .. (Respondent) Assessee by : Shri Deepak R Shah, A.R. Revenue by : Shri Kalpesh Rupavatiya, Sr. DR Date of Hearing 18/06/2026 Date of Pronouncement 19/06/2026 (आदेश)/ORDER Per Sanjay Garg, Judicial Member:

The present appeal has been filed by the Revenue against the order of the Ld. Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (hereinafter referred to as “NFAC”), Delhi (hereinafter referred to as “CIT(A)”), dated 20.02.2026 passed under Section 250 of the Income Tax Act, 1961 (hereinafter referred to as the “Act”) and relates to Assessment Year (A.Y.) 2018-19.

ITA No.1530/Ahd/2026[DCIT vs. Sagarlaxmi Agriseeds Private Limited] A.Y. 2018-19 - 2 –

Revenue in this appeal has taken following grounds of appeal:

“(a) On the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the addition of Rs. 4,14,84,571/- made by the AO on account of disallowance of depreciation on goodwill, without properly appreciating that no actual cost has been incurred and the goodwill has been artificially created through revaluation. (b) On the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in relying upon the decision of the Hon'ble ITAT in the assessee's own case for A.Y. 2017-18 without appreciating the factual and legal issues involved in the present year. (c) The appellant craves leave to add, alter, amend or modify any of the above -grounds of appeal at or before the time of hearing.”

At the outset, Ld. Counsel for the assessee has submitted that the sole issue raised by the Revenue relating to the depreciation on goodwill has already been decided in favour of the assessee by the Co-ordinate Bench of the Tribunal in the own case of the assessee for A.Y. 2017-18 vide order dated 05.08.2025 passed in ITA No.1918/Ahd/2024. He has further invited our attention to the impugned order of the Ld.CIT(A) to submit that the Ld.CIT(A) relying upon the said order of the ITAT has decided the same issue of depreciation on goodwill for the next year i.e. A.Y. 2018-19 in favour of the assessee.

The Ld. DR has not pointed out any distinguishing fact on the file for the assessment year under consideration. It is an

ITA No.1530/Ahd/2026[DCIT vs. Sagarlaxmi Agriseeds Private Limited] A.Y. 2018-19 - 3 –

admitted position by both the learned representatives of the parties that the facts and issue involved for the assessment year under consideration are identical to that have been discussed by this Tribunal in assessee’s appeal in ITA No.1918/Ahd/2024 vide order dated 05.08.2025 for immediately preceding year A.Y. 2017-18. In fact, assessment for the year under consideration i.e. A.Y. 2018-19 was reopened on the basis of A.Y. 2017-18 and the said issue already stood decided in favour of the assessee in the earlier assessment year. Therefore, the Ld.CIT(A) rightly followed the decision of the Tribunal for the assessment year under consideration. There is no merit in the present appeal of the Revenue and the same is, accordingly, dismissed.

In the result, the appeal of the Revenue stands dismissed.

This Order pronounced on 19/06/2026

Sd/- Sd/- (NARENDRA PRASAD SINHA) (SANJAY GARG) ACCOUNTANT MEMBER JUDICIAL MEMBER Ahmedabad; Dated 19/06/2026 S. K. SINHA True Copy आदेश क� �ितिल�प अ�े�षत/Copy of the Order forwarded to : अपीलाथ� / The Appellant 1. ��यथ� / The Respondent. 2. संबंिधत आयकर आयु� / Concerned CIT 3. आयकर आयु�(अपील) / The CIT(A)- 4. 5. �वभागीय �ितिनिध, आयकर अपीलीय अिधकरण, अहमदाबाद / DR, ITAT, Ahmedabad गाड� फाईल / Guard file. 6. आदेशानुसार/ BY ORDER,

उप/सहायक पंजीकार (Dy./Asstt. Registrar) आयकर अपीलीय अिधकरण, अहमदाबाद / ITAT, Ahmedabad

DCIT CIRCLE-4(1)(1), AHMEDABAD, VEJALPUR vs. SAGARLAXMI AGRISEEDS PRIVATE LIMITED, NAVRANGPURA

What did the Tribunal hold?

What were the facts?

What were the issues?

Which sections of the Income-tax Act were involved?

Recent GST High Court judgments