SAGARLAXMI AGRISEEDS PRIVATE LIMITED,AHMEDABAD vs. THE ACIT, CIRCLE-4(1)(1), AHMEDABAD

ITA 1918/AHD/2024Status: DisposedITAT Ahmedabad05 August 2025AY 2017-18Bench: S/SHRI SANJAY GARG, JUDICIAL MEMBER AND NARENDRA PRASAD SINHA (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the lower authorities erred in disallowing depreciation on purchased goodwill. The AO failed to rebut the valuation report supporting the goodwill's value and did not obtain the necessary approval to determine the actual cost.

What were the facts?

The assessee claimed depreciation on goodwill acquired from a proprietorship concern. The Assessing Officer disallowed this claim, arguing that the goodwill was not self-acquired by the proprietorship and its value was nil. The CIT(A) confirmed this disallowance.

What were the issues?

Whether depreciation on purchased goodwill is allowable when the valuation report is not rebutted by the revenue and whether the AO followed the correct procedure in determining the actual cost.

Which sections of the Income-tax Act were involved?

Section 32,Section 55(2)(a)(ii),Section 43(1)

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Income Tax Appellate Tribunal, “C” BENCH, AHMEDABAD

Before: S/SHRI SANJAY GARG & NARENDRA PRASAD SINHA

For Appellant: Shri Deepak R. Shah, AR
Hearing: 15/05/2025Pronounced: 05/08/2025

Per Sanjay Garg, Judicial Member

The above appeal has been preferred by the assessee against order passed by the Ld. Commissioner of Income-Tax(Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as “Ld. CIT(A)] dated 22.10.204 under section 250 of the Income Tax Act, 1961 ("the Act" for short) arising out of the order of passed by the Assessing Officer (hereinafter referred to as “AO”) under section 143(3) of the Act pertaining to Assessment Year 2017-18. 2. The assessee has raised the following grounds of appeal: Asst.Year: 2017-18 2

1.

Tha

The order continues below.

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