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“depreciation on goodwill”

DepreciationSection 32Section 32346 judgments

The decision most relied on for depreciation on goodwill is CIT v. Smifs Securities Ltd. (348 ITR 302), cited in 540 judgments on BharatTax.

Leading authorities on depreciation on goodwill

CIT v. Smifs Securities Ltd.
348 ITR 302 · 2012 · Supreme Court
540
citing judgments

Goodwill, whether arising from an amalgamation or a slump sale, is an intangible asset eligible for depreciation under Section 32(1) of the Income-tax Act. While the assessee must prove the existence and valuation of such goodwill, it is recognized as a depreciable asset.

Areva T&D India Ltd. v. DCIT
345 ITR 421 · 2012 · High Court
97
citing judgments

Business contracts and commercial rights of similar nature qualify as intangible assets under Section 32(1)(ii) and are eligible for depreciation. The decision also affirms that goodwill is an intangible asset eligible for depreciation.

Additional/Joint/Deputy/Assistant Commissioner of Incometax/Income-tax Officer v. Mylan Laboratories Ltd.
137 Taxmann.com 178 · 2022 · High Court
60
citing judgments

Goodwill arising on amalgamation is entitled to depreciation. This principle is established by multiple High Court decisions.

Beverages 331 ITR 192 (Del) B.Raveendran Pillai v. CIT
237 Taxmann 230 · 2016 · High Court
59
citing judgments

Goodwill arising on amalgamation is an intangible asset qualifying for depreciation under Section 32 of the Income Tax Act.

Ashwin Vanaspati Industries v. CIT
255 ITR 26 · 2002 · High Court
57
citing judgments

Depreciation is allowable on goodwill acquired through the slump sale of a business. When an assessee claims depreciation on the enhanced cost of an asset supported by a registered valuer's report, tax authorities must produce countervailing evidence, such as a departmental valuation report, to challenge it, rather than simply disregarding the expert opinion.

Kerala Vision Ltd. v. ACIT (
35 Taxmann.com 463 · 2013 · ITAT
52
citing judgments

Transactions carried out on the purchase of off-the-shelf software prior to the jurisdictional High Court's decision in CIT v. Samsung Electronics Co. Ltd. (October 15, 2011) are not liable for Tax Deducted at Source (TDS).

Thiru Arooran Sugar Ltd. v. DCIT
350 ITR 324 · 2013 · High Court
44
citing judgments

A deduction for interest expense on borrowed funds used for interest-free advances to group companies is permissible only if the assessee establishes these advances were from surplus funds. The decision further clarifies eligibility for depreciation on intangible assets like non-compete fees, software, goodwill, and commercial rights under section 32(1)(ii), often arising from a slump sale.

Triune Energy Services (P.) Ltd. v. DCIT
65 Taxmann.com 288 · 2016 · High Court
42
citing judgments

When a business is purchased as a going concern, the consideration paid in excess of the value of its tangible assets is classified as goodwill, which is an intangible asset eligible for depreciation without needing a separate valuation.

Judgments citing depreciation on goodwill

Incometax Officer, Chennai vs. Doosan Bobcat Private Limited, Chennai

In the result, the appeal of the Revenue is dismissed and the CO of assessee is dismissed as not-pressed

ITA 2288/CHNY/2025[2013]Status: DisposedITAT Chennai23 Jan 2026

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.2288/Chny/2025 & C.O No.76/Chny/2025 (Arising In Ita No.2288/Chny/2025) िनधा%रण वष% /Assessment Year: 2013-14 The Income Tax Officer, Doosan Bobcat Pvt. Ltd., Htc Towers, 6Th Floor, Corporate Ward-2(1), Vs. Chennai. No.41, Gst Road, Guindy Industrial Estate S.O., Guindy, Chennai – 600 032. Pan: Aaccd 6529L

For Respondent: Mr. Praveen.S, JCIT
Section 250Section 32Section 32(1)(ii)

No.2288/Chny/2025 & C.O No.76/Chny/2025 Doosan Bobcat Pvt. Ltd. :- 11 -: earned. Objective of calculating PLI is to get the best comparability possible. Non inclusion of depreciation on goodwill and non-compete fees in operating expense is nothing but an adjustment to increase the comparability between the two comparable. 11.1 Considering the facts ... transactions with the AEs, the same cannot be considered as an operating cost to compute the PLI for comparability. Accordingly, we hold that depreciation on goodwill and amortisation of non-compete fees is to be excluded by treating it as non-operating cost, being an extraordinary item for the purpose

Anshul Specialty Molecules Pvt Ltd, Mumbai vs. DCIT, Circle 1(1)(1), Mumbai

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

ITA 7503/MUM/2025[2020-21]Status: DisposedITAT Mumbai22 Jan 2026AY 2020-21

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokaranshul Speciality Dcit Circle Molecules Private 1(1)(1), Mumbai Limited Vs. Aayakar Bhawani, Flexcel Park, „C‟ Wing, S.V. Mumbai-400 020 Road, Nr. 24 Karat Multiplex, Jogeshwari (W), Mumbai- 400102 Pan/Gir No. Aabca4003H (Applicant) (Respondent) Assessee By Shri H. N. Motiwala, Revenue By Shri Surendra Mohan, Sr. Dr Date Of Hearing 20.01.2026 Date Of Pronouncement 22.01.2026

Section 142(1)Section 143(1)Section 143(3)Section 144BSection 250Section 270ASection 32(1)Section 32(1)(ii)

amounting to Rs. 1,22,44,409/-, under section 32(1)(ii) of the Act. The Assessing Officer examined the claim of depreciation on goodwill and issued notices under section 142(1) calling upon the assessee to furnish details 3 Anshul Specialty Molecules Pvt Ltd regarding the method of valuation ... restriction under the proviso to section 32(1) applies, valuation of goodwill becomes irrelevant. Thus, the learned CIT(A) confirmed the disallowance of depreciation on goodwill and dismissed related ground of the appeal. 5 Anshul Specialty Molecules Pvt Ltd 8. Aggrieved by the order of the learned

Assisstant Commissioner of Income Tax Corporate Circle 1 1, Chennai vs. Fl Smith Private Limited, Kanchipuram

ITA 1763/CHNY/2024[2017-18]Status: DisposedITAT Chennai21 Jan 2026AY 2017-18

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1682/Chny/2024 & Co No.71/Chny/2024 (In Ita No.: 1682/Chny/2024) निर्धारण वर्ष / Assessment Year: 2015-16 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. (अपीलार्थी/Appellant) [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent/ Cross Objector) आयकर अपील सं./Ita Nos.: 1731 & 1763/Chny/2024 निर्धारण वर्ष / Assessment Years: 2014-15 & 2017-18 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. [Pan: Aaacf-4997-N] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Department By : Shri. P.M.Kathir, Advocate & Shri S.P.Chidambaram, Advocate : Shri. A R V Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement आदेश /O Rder : 15.12.2025 : 21.01.2026 Per Bench: These Appeals Filed By The Revenue & Cross Objection Filed By The Assessee Are Arising Out Of Order Of The Commissioner Of Income Tax (Appeals)-16, Chennai (In Short “Ld.Cit(A)”) Against Orders U/S.143(3) R.W.S. 92Ca(3) R.W.S 144C Of The Income Tax Act, 1961 (Hereinafter The ‘Act') For The

For Respondent: Shri. P.M.Kathir, Advocate and
Section 143(3)Section 43(1)Section 43(6)

been raised by the assessee for the A.Y.2015-16 only. Since the facts are common/identical and the issue of assessee's claim of depreciation on goodwill arising on amalgamation, is common for these three assessment years, for the sake of convenience, the appeals filed by the Revenue are being heard together

Assisstant Commissioner of Income Corporate Circle 1-1, Chennai vs. Fl Smidth Private Limited, Kanchipuram

ITA 1731/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Jan 2026AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1682/Chny/2024 & Co No.71/Chny/2024 (In Ita No.: 1682/Chny/2024) निर्धारण वर्ष / Assessment Year: 2015-16 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. (अपीलार्थी/Appellant) [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent/ Cross Objector) आयकर अपील सं./Ita Nos.: 1731 & 1763/Chny/2024 निर्धारण वर्ष / Assessment Years: 2014-15 & 2017-18 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) Assessee By Department By : Shri. P.M.Kathir, Advocate & Shri S.P.Chidambaram, Advocate : Shri. A R V Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement आदेश /O Rder : 15.12.2025 : 21.01.2026 Per Bench: These Appeals Filed By The Revenue & Cross Objection Filed By The Assessee Are Arising Out Of Order Of The Commissioner Of Income Tax (Appeals)-16, Chennai (In Short "Ld.Cit(A)") Against Orders U/S.143(3) R.W.S. 92Ca(3) R.W.S 144C Of The Income Tax Act, 1961 (Hereinafter The 'Act') For The

For Respondent: Shri. P.M.Kathir, Advocate and
Section 143(3)Section 43(1)Section 43(6)

been raised by the assessee for the A.Y.2015-16 only. Since the facts are common/identical and the issue of assessee's claim of depreciation on goodwill arising on amalgamation, is common for these three assessment years, for the sake of convenience, the appeals filed by the Revenue are being heard together

Assisstant Commisioner of Income Tax Corporate Circle 1 1, Chennai vs. Fl Smith Private Limited, Kanchipuram

ITA 1682/CHNY/2024[2015-16]Status: DisposedITAT Chennai21 Jan 2026AY 2015-16

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita No.: 1682/Chny/2024 & Co No.71/Chny/2024 (In Ita No.: 1682/Chny/2024) निर्धारण वर्ष / Assessment Year: 2015-16 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. (अपीलार्थी/Appellant) [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent/ Cross Objector) आयकर अपील सं./Ita Nos.: 1731 & 1763/Chny/2024 निर्धारण वर्ष / Assessment Years: 2014-15 & 2017-18 Assistant Commissioner Of Income Tax, Corporate Circle-1(1) Chennai. Flsmidth Private Limited, Vs. 34Th Egatoor, Flsmidth House, Rajiv Gandhi Salai, Kelambakkam, Kanchipuram – 603 103. [Pan: Aaacf-4997-N] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) Assessee By Department By : Shri. P.M.Kathir, Advocate & Shri S.P.Chidambaram, Advocate : Shri. A R V Sreenivasan, Cit. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement आदेश /O Rder : 15.12.2025 : 21.01.2026 Per Bench: These Appeals Filed By The Revenue & Cross Objection Filed By The Assessee Are Arising Out Of Order Of The Commissioner Of Income Tax (Appeals)-16, Chennai (In Short “Ld.Cit(A)”) Against Orders U/S.143(3) R.W.S. 92Ca(3) R.W.S 144C Of The Income Tax Act, 1961 (Hereinafter The ‘Act') For The

For Respondent: Shri. P.M.Kathir, Advocate and
Section 143(3)Section 43(1)Section 43(6)

been raised by the assessee for the A.Y.2015-16 only. Since the facts are common/identical and the issue of assessee's claim of depreciation on goodwill arising on amalgamation, is common for these three assessment years, for the sake of convenience, the appeals filed by the Revenue are being heard together

ACIT- 6(1)(2), Mumbai vs. Siyaram Silk Mills Limited, Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 5692/MUM/2025[2017-18]Status: DisposedITAT Mumbai07 Jan 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

Section 143(3)Section 250Section 32

assessee. The said ground of appeal was allowed. Being aggrieved, revenue filed an appeal before us. 3. The Ld.AR stated that the depreciation on goodwill upon amalgamation was duly accounted for in books of accounts in earlier years, i.e. for the assessment year 2016-17. The assessee has claimed ... depreciation on goodwill on earlier year and impugned assessment year. The instant year is the second year of such claim. He stated that as per the scheme of amalgamation approved by Hon’ble Bombay High Court, M/s Balakrishna Synthetics Limited has acquired by assessee with effect from 01/04/2015

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

ITA 7294/MUM/2018[2014-15]Status: DisposedITAT Mumbai02 Jan 2026AY 2014-15

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)

aforesaid decision, are reproduced as follows: - "5.18 We have heard rival submission of parties. The issue in dispute is claim of depreciation on Goodwill recognised by the assessee in two transaction of acquisition of two units. The assessee claimed that those acquisitions are for purchase of unit for lumpsum consideration ... liabilities as goodwill and allow the depreciation on same to the assessee under the provisions of the Act. On similar lines, the depreciation on goodwill amounting to INR 15,96,20,019 claimed by the assessee in the year under consideration is also allowed. As a result, grounds no.2-5, raised

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2014-

ITA 7393/MUM/2017[2013-14]Status: DisposedITAT Mumbai02 Jan 2026AY 2013-14

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 32(1)

aforesaid decision, are reproduced as follows: - "5.18 We have heard rival submission of parties. The issue in dispute is claim of depreciation on Goodwill recognised by the assessee in two transaction of acquisition of two units. The assessee claimed that those acquisitions are for purchase of unit for lumpsum consideration ... liabilities as goodwill and allow the depreciation on same to the assessee under the provisions of the Act. On similar lines, the depreciation on goodwill amounting to INR 15,96,20,019 claimed by the assessee in the year under consideration is also allowed. As a result, grounds no.2-5, raised

Thermo Fisher Scientific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

ITA 577/MUM/2017[2012-13]Status: DisposedITAT Mumbai02 Jan 2026AY 2012-13

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 144C(5)Section 32(1)

aforesaid decision, are reproduced as follows: - "5.18 We have heard rival submission of parties. The issue in dispute is claim of depreciation on Goodwill recognised by the assessee in two transaction of acquisition of two units. The assessee claimed that those acquisitions are for purchase of unit for lumpsum consideration ... liabilities as goodwill and allow the depreciation on same to the assessee under the provisions of the Act. On similar lines, the depreciation on goodwill amounting to INR 15,96,20,019 claimed by the assessee in the year under consideration is also allowed. As a result, grounds no.2-5, raised

Thermo Fisher Scienftific India P. Ltd, Mumbai vs. DCIT 15(3)(1), Mumbai

In the result, the appeal by the assessee for the assessment year 2014-

ITA 1236/MUM/2016[2011-12]Status: DisposedITAT Mumbai02 Jan 2026AY 2011-12

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri Dhanesh Bafna, Shri Anmol MahajanFor Respondent: Shri Pravin Salunkhe, Sr.DR
Section 143(3)Section 144C(13)Section 32(1)

aforesaid decision, are reproduced as follows: - "5.18 We have heard rival submission of parties. The issue in dispute is claim of depreciation on Goodwill recognised by the assessee in two transaction of acquisition of two units. The assessee claimed that those acquisitions are for purchase of unit for lumpsum consideration ... liabilities as goodwill and allow the depreciation on same to the assessee under the provisions of the Act. On similar lines, the depreciation on goodwill amounting to INR 15,96,20,019 claimed by the assessee in the year under consideration is also allowed. As a result, grounds no.2-5, raised

DCIT, Bangalore vs. M/S Thomson Reuters India Services Pvt. Ltd., Bangalore

In the result, appeal filed by revenue in IT(TP)

ITA 843/BANG/2015[2010-11]Status: DisposedITAT Mumbai31 Dec 2025AY 2010-11

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 10ASection 10A(2)Section 143(3)

That on the facts and circumstances of the case, the learned AO and the learned Panel erred in denying the claim for depreciation on goodwill under section 32 of the Act in respect of undertaking acquired from Thomson Business Information India Private Limited (TBI) and RIPL. b) That the learned ... making disallowance u/s 10A in respect of Titanium STPI unit amount to Rs. 34,64,35,220/-. • Denying claim of depreciation on goodwill in respect of the undertaking acquired by slum sale amounting to Rs.9,01,44,504/- • Disallowance of depreciation of software items u/s 40(a)(ia) amounting

M/S Thomson Reuters International Services Private Limited, Mumbai vs. DCIT, Bangalore

ITA 542/BANG/2015[2010-11]Status: DisposedITAT Mumbai31 Dec 2025AY 2010-11

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 10ASection 10A(2)Section 143(3)

That on the facts and circumstances of the case, the learned AO and the learned Panel erred in denying the claim for depreciation on goodwill under section 32 of the Act in respect of undertaking acquired from Thomson Business Information India Private Limited (TBI) and RIPL. b) That the learned

DCIT, Bangalore vs. M/S Thomson Corporation (International) Pvt. Ltd., Bangalore

ITA 234/BANG/2015[2010-11]Status: DisposedITAT Mumbai31 Dec 2025AY 2010-11

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

Section 10ASection 10A(2)Section 143(3)Section 7A

That on the facts and circumstances of the case, the learned AO and the learned Panel erred in denying the claim for depreciation on goodwill under section 32 of the Act in respect of undertaking acquired from Thomson Business Information India Private Limited (TBI) and RIPL. b) That the learned

Vama International, Mumbai vs. ACIT 22(3), Mumbai

In the result, the appeal of the assessee is allowed

ITA 5456/MUM/2025[2012-13]Status: DisposedITAT Mumbai17 Dec 2025AY 2012-13

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Dharan Gandhi, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)
Section 143(1)Section 147Section 148

income filed by assessee, particularly the notes and schedule attached to the balance sheet clearly showed that all facts relating to claim of depreciation on goodwill had been fully disclosed by the assessee. As there was no failure on the part of the assessee to disclose ell facts, the reopening

Joshi Technologies International Inc India Projects, Ahmedabad vs. The ACIT (Int. Taxa-1), Ahmedabad

In the result, all the three appeals filed by the assessee are partly allowed

ITA 81/AHD/2022[2018-19]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2018-19

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R
Section 143(3)Section 32Section 80I

well. Thus, Ground No. 2, 2.1 to 2.6 are allowed. 9. As regards to Ground No. 3 and 3.1 relating to disallowance on depreciation of goodwill under Section 32 of the Act, the Ld. AR submitted that participating interest of L&T in JV were transferred to assessee vide agreement ... amount so paid in excess of consideration over the net identifiable fixed assets to acquire commercial right was recognized as “Goodwill” and depreciation on goodwill was claimed and allowed in previous years. In the present Assessment Year, the assessee has claimed depreciation on goodwill at the rate

Joshi Technologies International Inc India Projects, Ahmedabad vs. The ACIT (Int. Taxa-1), Ahmedabad

In the result, all the three appeals filed by the assessee are partly allowed

ITA 80/AHD/2022[2017-18]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2017-18

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R
Section 143(3)Section 32Section 80I

well. Thus, Ground No. 2, 2.1 to 2.6 are allowed. 9. As regards to Ground No. 3 and 3.1 relating to disallowance on depreciation of goodwill under Section 32 of the Act, the Ld. AR submitted that participating interest of L&T in JV were transferred to assessee vide agreement ... amount so paid in excess of consideration over the net identifiable fixed assets to acquire commercial right was recognized as “Goodwill” and depreciation on goodwill was claimed and allowed in previous years. In the present Assessment Year, the assessee has claimed depreciation on goodwill at the rate

Joshi Technologies International Inc India Projects, Ahmedabad vs. Assistant Commissioner of Income Tax, Circle(Int.Taxn.)-1, Ahmedabad

In the result, all the three appeals filed by the assessee are partly allowed

ITA 244/AHD/2022[2019-20]Status: DisposedITAT Ahmedabad12 Dec 2025AY 2019-20

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleita Nos. 80, 81 & 244/Ahd/2022 (Assessment Years 2017-18, 2018-19 & 2019-20)

For Appellant: Shri Vishal Kalra, A.RFor Respondent: Shri Sher Singh, CIT-D.R
Section 143(3)Section 32Section 80I

well. Thus, Ground No. 2, 2.1 to 2.6 are allowed. 9. As regards to Ground No. 3 and 3.1 relating to disallowance on depreciation of goodwill under Section 32 of the Act, the Ld. AR submitted that participating interest of L&T in JV were transferred to assessee vide agreement ... amount so paid in excess of consideration over the net identifiable fixed assets to acquire commercial right was recognized as “Goodwill” and depreciation on goodwill was claimed and allowed in previous years. In the present Assessment Year, the assessee has claimed depreciation on goodwill at the rate

Srf Limited, Delhi vs. Assistant / Deputy Commissioner of Income Tax, Circle 10(1), New Delhi, Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 5618/DEL/2024[2021-22]Status: DisposedITAT Delhi12 Dec 2025AY 2021-22
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

delete the disallowance of deduction u/s 80-IA of the Act amounting to Rs.54,91,48,703/-. XI. Disallowance of Depreciation of Goodwill amounting to Rs. 10,77,290/- 59.0 That the Ld. DRP and consequently the Ld. AO have erred in law and on the facts & circumstances ... assessee’s own case. 62.0 The Hon’ble ITAT may be pleased to grant the allowance of depreciation on Goodwill of Rs. 10,77,290/-. XII. Disallowance u/s 14A of the Act amounting to Rs. 1,25,14,370/- 63.0 That the Ld. DRP and consequently the Ld. AO have

Srf Limited, Delhi vs. ACIT, Circle-10(1), Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1449/DEL/2022[2018-19]Status: DisposedITAT Delhi12 Dec 2025AY 2018-19
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

delete the disallowance of deduction u/s 80-IA of the Act amounting to Rs.54,91,48,703/-. XI. Disallowance of Depreciation of Goodwill amounting to Rs. 10,77,290/- 59.0 That the Ld. DRP and consequently the Ld. AO have erred in law and on the facts & circumstances ... assessee’s own case. 62.0 The Hon’ble ITAT may be pleased to grant the allowance of depreciation on Goodwill of Rs. 10,77,290/-. XII. Disallowance u/s 14A of the Act amounting to Rs. 1,25,14,370/- 63.0 That the Ld. DRP and consequently the Ld. AO have

Srf Limited, New Delhi vs. ACIT, Circle-10(1), Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1448/DEL/2022[2017-18]Status: DisposedITAT Delhi12 Dec 2025AY 2017-18
For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 143(3)Section 144C(13)Section 144C(5)Section 80Section 92C

delete the disallowance of deduction u/s 80-IA of the Act amounting to Rs.54,91,48,703/-. XI. Disallowance of Depreciation of Goodwill amounting to Rs. 10,77,290/- 59.0 That the Ld. DRP and consequently the Ld. AO have erred in law and on the facts & circumstances ... assessee’s own case. 62.0 The Hon’ble ITAT may be pleased to grant the allowance of depreciation on Goodwill of Rs. 10,77,290/-. XII. Disallowance u/s 14A of the Act amounting to Rs. 1,25,14,370/- 63.0 That the Ld. DRP and consequently the Ld. AO have