ACIT CC-1(3), AHMEDABAD, AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

ITA 896/AHD/2025Status: DisposedITAT Ahmedabad25 February 2026AY 2017-18Bench: Shri Sanjay Garg (Judicial Member), Shri Narendra Prasad Sinha (Accountant Member)16 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that depreciation on goodwill arising from amalgamation is an allowable deduction, following its own prior decisions and High Court pronouncements. The Tribunal also found that the Assessing Officer erred in invoking Rule 8D for disallowance under Section 14A without recording the necessary dissatisfaction.

What were the facts?

The assessee claimed depreciation on goodwill arising from a scheme of amalgamation. The Assessing Officer disallowed this claim, citing provisions of the Income Tax Act and previous disallowances. The assessee argued that the issue of depreciation on goodwill had been decided in its favor by the Tribunal in prior years.

What were the issues?

Whether depreciation on goodwill arising from amalgamation is allowable, and whether disallowance under Section 14A was validly made without prerequisite satisfaction.

Which sections of the Income-tax Act were involved?

Section 32(1),Section 49(1)(iii)(e),Section 43(1),Section 43(6)(c),Section 55(2)(a)(ii),Section 14A

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(4)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

आयकर अपीलीय अिधकरण, अहमदाबाद "ायपीठ “ए“,अहमदाबाद । IN THE INCOME TAX APPELLATE TRIBUNAL “ A ” BENCH, AHMEDABAD

"ी संजय गग", "ाियक सद" एवं "ी नरे !साद िस"ा, लेखा सद" के सम%।

Before Shri Sanjay Garg, Judicial Member And Shri Narendra Prasad Sinha, Accountant Member आयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(s) by : ITA No(s) Assess- No(s) अपीलाथ' / !(थ' / ment Appellant बनाम/vs. Respondent Year(s) 893/Ahd/2025 1. 2016-17 The ACIT Unicorn Packaging Central Circle LLP 1(3) Urmin House Ahmedabad – Ground Floor 380 014 Sindhu Bhavan Road B/S. HOF Living Off. SG Highway Bodakdev Ahmedabad – 380 059 PAN: AAEFU 5939 L (Assessee) (Revenue) 2. 894/Ahd/2025 2016-17 Revenue -do-Assessee 3. 895/Ahd/2025 2016-17 Revenue Unicorn Packaging Pvt.Ltd. (address as above) PAN : AABCU 2453 M 4. 896/Ahd/2025 2017-18 Revenue Unicorn Packaging LLP (address as above) 897/Ahd/2025 5. 2018-19 Revenue -do-Assessee 6. 898/Ahd/2025 2020-21 Revenue -do-Assessee

Assessee by : Shri Aseem L. Thakkar, AR Revenue by : Shri Alpesh Parmar, CIT-DR

सुनवाई की तारीख/Date of Hearing : 28/11.2025 घोषणा की तारीख /Date of Pronouncement: 25/02/2026

ITA Nos.893, 894, 896 to 898/Ahd/2025 ACIT vs. Unicorn Packaging LLP & Asst.

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.

Create a free accountSign in

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(1)

All 386 judgments and leading authorities on Section 32(1) →

Recent GST High Court judgments

Search GST case law →