Chitra Publicity Co. (P) Ltd. v. ACIT

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

In the result, appeal of the assessee stands allowed

Bench: S/Shri Sanjay Garg & Narendra Prasad Sinhaassessment Year : 2017-18 Sagarlaxmi Agriseeds Pvt Ltd Acit, Cir.4(1)(1) 206, Ashwamegh Avenue Vs Ahmedabad. Opp: Mithakhali Garden Navrangpura Ahmedabad. Pan : Aawcs 7561 F (Respondent) (Appellant) Assessee By : Shri Deepak R. Shah, Ar Revenue By : Shri Dharnidas V.S., Sr.Dr सुनवाई की तारीख/Date Of Hearing : 15/05/2025 घोषणा की तारीख /Date Of Pronouncement: 05/08/2025 आदेश/O R D E R

…nnot be applied. Sagarlaxmi Agriseeds Pvt.Ltd. vs. ACIT Asst.Year: 2017-18 16 13.1. The Ld. Counsel has further placed reliance on the Third member decision of coordinate Ahmedabad Bench of the Tribunal in the case of “Chitra Publicity Pvt Ltd.” reported in (127 TTJ 1) and has contended that in the said case also, on transfer of a business of erstwhile firm to a company, the enhanced cost of an intangible asset which was not in books of erstwhile firm which having been paid for by way of issue of shares, it was held that in view of explanation 3 to section 43(1) of the Act, the AO was supposed to record satisfac…