Aricent Technologies (Holdings) Ltd. v. DCIT

33 DTR 148Income Tax Appellate Tribunal2010#11496 most cited
9

judgments rely on this decision, according to BharatTax’s citation analysis of 341,001 Indian tax judgments — from 2022 to 2025.

Sections most often in play

Section 115JBSection 35ADSection 35AD(7B)Section 14ASection 35AD(7A)Section 69ASection 143(3)Section 153A

Issues it is cited on

section 2(19aa)section 35adcommercial substanceresulting companynav methodtransferee companydepreciation on goodwilltransferor companyslump saledcf methodscheme of arrangementsection 43(1)

Judgments citing Aricent Technologies (Holdings) Ltd. v. DCIT

Mahadhan Agritech Limited (Formerly Known As Smartchem Technologies Ltd), Mumbai vs. Assistant Commissioner of Income Tax Central Circle 8(1), Mumbai

In the result, the appeals filed by the assessee are

ITA 5423/MUM/2024[2020-21]Status: DisposedITAT Mumbai24 Jul 2025AY 2020-21
Section 115JSection 132Section 143(3)Section 153ASection 69A

…instant case. Towards this, reliance was placed, on the below decisions: - Aricent Technologies (Holdings) Ltd. v. DCIT (2019) 109 48 ITA No.2227/Mum/2024 and others Mahadhan Agritech Limited taxmann.com 47 (Delhi ITAT) - A.P. Paper Mills Ltd. vs. ACIT (2010) 33 DTR 148 (Hyd. ITAT) 55. Further, the sixth proviso to Sec. 32(1) does not apply for assets on which depreciation has never been claimed by the transferor company towards which reliance was placed on the following decisions: - Triune Energy Services (P) Ltd. v. DCIT [2016] 237 Taxman 230 (Del. HC) - Urmin Marketing P. Ltd. v. DCIT [2020] 122 taxmann.com 40…

Mahadhan Agritech Limited (Formerly Known As Smartchem Technologies Limited ), Mumbai vs. Deputy Commissioner of Income Tax, Central Circle -8(1), Mumbai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 3937/MUM/2024[2019-20]Status: DisposedITAT Mumbai24 Jul 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

…s Explanation 7A to Sec. 43(1) is also not applicable in the instant case. Towards this, reliance was placed, on the below decisions: - Aricent Technologies (Holdings) Ltd. v. DCIT (2019) 109 taxmann.com 47 (Delhi ITAT) - A.P. Paper Mills Ltd. vs. ACIT (2010) 33 DTR 148 (Hyd. ITAT) 55. Further, the sixth proviso to Sec. 32(1) does not apply for assets on which depreciation has never been claimed by the transferor company towards which reliance was placed on the following decisions: - Triune Energy Services (P) Ltd. v. DCIT [2016] 237 Taxman 230 (Del. HC) Urmin Marketing P. Ltd. v. DCIT [2020] 122 - taxmann.com 4…

DCIT Central Circle 8(1), Mumbai vs. Mahadhan Agritech Limited, Pune

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 3569/MUM/2024[2019-20]Status: DisposedITAT Mumbai24 Jul 2025AY 2019-20

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

…s Explanation 7A to Sec. 43(1) is also not applicable in the instant case. Towards this, reliance was placed, on the below decisions: - Aricent Technologies (Holdings) Ltd. v. DCIT (2019) 109 taxmann.com 47 (Delhi ITAT) - A.P. Paper Mills Ltd. vs. ACIT (2010) 33 DTR 148 (Hyd. ITAT) 55. Further, the sixth proviso to Sec. 32(1) does not apply for assets on which depreciation has never been claimed by the transferor company towards which reliance was placed on the following decisions: - Triune Energy Services (P) Ltd. v. DCIT [2016] 237 Taxman 230 (Del. HC) Urmin Marketing P. Ltd. v. DCIT [2020] 122 - taxmann.com 4…

Mahadhan Agritech Limited (Formerly Known As Smartchem Technologies Ltd, Mumbai vs. Commissioner of Income Tax(Appeal)--50, Mumai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 2229/MUM/2024[2018-19]Status: DisposedITAT Mumbai24 Jul 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

…s Explanation 7A to Sec. 43(1) is also not applicable in the instant case. Towards this, reliance was placed, on the below decisions: - Aricent Technologies (Holdings) Ltd. v. DCIT (2019) 109 taxmann.com 47 (Delhi ITAT) - A.P. Paper Mills Ltd. vs. ACIT (2010) 33 DTR 148 (Hyd. ITAT) 55. Further, the sixth proviso to Sec. 32(1) does not apply for assets on which depreciation has never been claimed by the transferor company towards which reliance was placed on the following decisions: - Triune Energy Services (P) Ltd. v. DCIT [2016] 237 Taxman 230 (Del. HC) Urmin Marketing P. Ltd. v. DCIT [2020] 122 - taxmann.com 4…

Mahadhan Agritech Limited (Formerly Knwon As Smartech Technologies Ltd ), Mumbai vs. Commissioner of Income Tax (Appeals)-Mumbai-50, Mumbai

In the result, the appeals filed by the assessee are

ITA 2228/MUM/2024[2016-17]Status: DisposedITAT Mumbai24 Jul 2025AY 2016-17
Section 115JSection 132Section 143(3)Section 153ASection 69A

…nstant case. Towards this, reliance was placed, on the below decisions: - Aricent Technologies (Holdings) Ltd. v. DCIT (2019) 109 ITA No.2227/Mum/2024 and others Mahadhan Agritech Limited 49 taxmann.com 47 (Delhi ITAT) - A.P. Paper Mills Ltd. vs. ACIT (2010) 33 DTR 148 (Hyd. ITAT) 55. Further, the sixth proviso to Sec. 32(1) does not apply for assets on which depreciation has never been claimed by the transferor company towards which reliance was placed on the following decisions: - Triune Energy Services (P) Ltd. v. DCIT [2016] 237 Taxman 230 (Del. HC) - Urmin Marketing P. Ltd. v. DCIT [2020] 122 taxmann.com 40…

Mahadhan Agritech Limited (Formerly Known As Smartech Technologies Ltd, Mumbai vs. Commissioner of Income Tax (Appeals)-Mumbai.50, Mumbai

In the result, the appeals filed by the assessee are allowed, and the appeal filed by the Revenue is dismissed

ITA 2227/MUM/2024[2017-18]Status: DisposedITAT Mumbai24 Jul 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115JSection 132Section 143(3)Section 153ASection 69A

…s Explanation 7A to Sec. 43(1) is also not applicable in the instant case. Towards this, reliance was placed, on the below decisions: - Aricent Technologies (Holdings) Ltd. v. DCIT (2019) 109 taxmann.com 47 (Delhi ITAT) - A.P. Paper Mills Ltd. vs. ACIT (2010) 33 DTR 148 (Hyd. ITAT) 55. Further, the sixth proviso to Sec. 32(1) does not apply for assets on which depreciation has never been claimed by the transferor company towards which reliance was placed on the following decisions: - Triune Energy Services (P) Ltd. v. DCIT [2016] 237 Taxman 230 (Del. HC) Urmin Marketing P. Ltd. v. DCIT [2020] 122 - taxmann.com 4…

Pfizer Ltd, Mumbai vs. DCIT - 14(2) (2), Mumbai

In the result, appeal filed by the assessee is partly allowed

ITA 2132/MUM/2018[2014-15]Status: DisposedITAT Mumbai22 Sept 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Pfizer Limited The Capital, 1802/1901, Acit-14(2)(2) Plot No.C-70, G-Block, 461, 4T H Floor, Aaykar Bhavan Bandra Kurla Complex, Vs. Mumbai-400 020 Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaacp3334M

For Appellant: Shri P.J. Pardiwala Sr. AdvocateFor Respondent: Shri Ajay Kumar Sharma, CIT
Section 32Section 35D

…y relying on several judicial precedents:- i. M/s Toyo engineering India private limited ITA number 3279/M/2008 dated 13/10/2014 ii. Cosmos cooperative bank Ltd 64 SOT 90 iii. Shri Krishna drugs limited ITA number 198/Hyderabad/2011 iv. AP paper Mills Ltd 33 DTR 148 v. Mylan laboratories Ltd 180 ITD 558 vi. Arricent technologies Holdings Ltd ITA number 19/del/2013 vii. Urmin marketing private limited ITA number 1806/Ahmedabad /2019 viii. JX Nippon lubricants private limited 4985/Del/ 2019 ITA No.2108, 2132/Mum/2018 & CO 110/Mum/2019; A.Y. 2014-15 ix. classic strips private limited versus DCIT ITA number 2…

ACIT - 14(2) (2), Mumbai vs. Pfizer Ltd, Mumbai

In the result, appeal filed by the assessee is partly allowed

ITA 2108/MUM/2018[2014-15]Status: DisposedITAT Mumbai22 Sept 2023AY 2014-15

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Pfizer Limited The Capital, 1802/1901, Acit-14(2)(2) Plot No.C-70, G-Block, 461, 4T H Floor, Aaykar Bhavan Bandra Kurla Complex, Vs. Mumbai-400 020 Bandra (East), Mumbai-400 051 (Appellant) (Respondent) Pan No. Aaacp3334M

For Appellant: Shri P.J. Pardiwala Sr. AdvocateFor Respondent: Shri Ajay Kumar Sharma, CIT
Section 32Section 35D

…y relying on several judicial precedents:- i. M/s Toyo engineering India private limited ITA number 3279/M/2008 dated 13/10/2014 ii. Cosmos cooperative bank Ltd 64 SOT 90 iii. Shri Krishna drugs limited ITA number 198/Hyderabad/2011 iv. AP paper Mills Ltd 33 DTR 148 v. Mylan laboratories Ltd 180 ITD 558 vi. Arricent technologies Holdings Ltd ITA number 19/del/2013 vii. Urmin marketing private limited ITA number 1806/Ahmedabad /2019 viii. JX Nippon lubricants private limited 4985/Del/ 2019 ITA No.2108, 2132/Mum/2018 & CO 110/Mum/2019; A.Y. 2014-15 ix. classic strips private limited versus DCIT ITA number 2…

Dy. Commissioner of Income Tax, Circle-16(2), Hyderabad vs. Eenadu Television Private Limited, Hyderabad

In the result, the appeal of Revenue is partly allowed for statistical purposes

ITA 2244/HYD/2018[2015-16]Status: DisposedITAT Hyderabad22 Jul 2022AY 2015-16

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri V. Siva KumarFor Respondent: Shri Rajendra Kumar, CIT
Section 115JSection 143(3)Section 251(1)

…sistant Commissioner of Income Tax • [2009] 33 SOT 237 (Mum - ITAT) • Hindustan Coca Cola Beverages (P) Ltd. vs. DCIT [2009] 34 SOT 171 (Del - ITAT) • Skyline Caterers (P) Ltd. vs. ITO [2008] 116 ITD 348 (Mum - ITAT) • The A.P Paper Mills Ltd. vs. ACIT [2010] 33 DTR 148 (Hyd - ITAT) • CLC Global Limited [ITA No. 2288/De1/08](Del). • Hindustan Coca Cola Beverages Pvt. Ltd [ITA No. 1391/2010, 1394/2010 & 1396/2010] (Del) 7 2.11 Therefore in view of the above decisions, the Appellant submits that the depreciation claimed on non-compete rights acquired from UKM and UKTV by UEPL which devolved onto the appellant is a…

Aricent Technologies (Holdings) Ltd. v. DCIT (33 DTR 148) — Cited in 9 Judgments | BharatTax