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“intangible assets”

DepreciationSection 32(1)(ii)Section 32(1)(ii)1,121 judgments

The decision most relied on for intangible assets is CIT v. B.C. Srinivasa Setty (128 ITR 294), cited in 628 judgments on BharatTax.

Leading authorities on intangible assets

CIT v. B.C. Srinivasa Setty
128 ITR 294 · 1981 · Supreme Court
628
citing judgments

When the cost of acquisition of a capital asset cannot be determined, the computation mechanism for capital gains fails, and thus no capital gains can be charged. This establishes a broader principle that a charging section cannot operate in the absence of specific machinery provisions for computation.

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.

Techno Shares and Stocks Ltd. v. CIT
327 ITR 323 · 2010 · Supreme Court
130
citing judgments

Membership rights and business contracts, as 'business or commercial rights of similar nature' to a license or franchise, qualify as intangible assets eligible for depreciation under Section 32(1)(ii) of the Income-tax Act.

Amway India Enterprises v. DCIT
111 ITD 112 · 2008 · ITAT
127
citing judgments

Depreciation is allowable on computer software, including software licenses, at the rate of 60%.

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.

CIT v. Tata Services Ltd.
122 ITR 594 · 1980 · High Court
76
citing judgments

A right to purchase property under an agreement to sell is a capital asset as defined under Section 2(14) of the Income-tax Act. The relinquishment or extinguishment of such a right constitutes a transfer of a capital asset, the consideration for which is taxable as capital gains.

Guffic Chem (P.) Ltd. v. CIT
332 ITR 602 · 2011 · Supreme Court
66
citing judgments

Compensation received for a non-compete covenant or for not carrying on a specific business activity is a capital receipt and not liable to tax as business income.

ACIT v. Progressive Constructions Ltd.
92 Taxmann.com 104 · 2018 · ITAT
63
citing judgments

Rights acquired under a concession agreement for highway construction, which generate revenue through toll collections, constitute an 'intangible asset' under section 32(1)(ii) of the Income-tax Act, 1961, eligible for depreciation, typically at 25%. This includes claiming depreciation on the opening Written Down Value (WDV) for such highway projects.

Judgments citing intangible assets

Coromandel International Limited, Hyderabad vs. DCIT., Circle-2(2), Hyderabad

In the result the appeal of the assessee is partly allowed for statistical purposes

ITA 738/HYD/2025[2015-2016]Status: DisposedITAT Hyderabad18 Mar 2026AY 2015-2016

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.738/Hyd/2025 ("नधा"रणवष"/ Assessment Year:2015-16) Coromandel International Vs. Dcit, Limited, Circle-2(2), Hyderabad. Hyderabad. Pan: Aaacc7852K (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Sp Chidambaram, Advocate Assessee Represented By राज"वका""त"न"ध"व/ : Ms. U. Mini Chandran, Cit-Dr Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 02/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 18/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Coromandel International Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 24/02/2025 For The Assessment Year (“A.Y.”) 2015-16. Page 1 Of 17 Coromandel International Limited Vs. Dcit 2. The Assessee Has Raised The Following Grounds Of Appeal:

Section 250Section 32Section 32(1)(ii)Section 35

whether it is actually claimed by the Assessee in the return of income. d. The denial of depreciation on goodwill, being a recognized depreciable intangible asset under Section 32(1)(ii), on account of a procedural lapse, is in clear contravention of statutory provisions and settled judicial principles, and therefore ... same as goodwill in its books of account. It is an admitted position that the assessee did not capitalise the said amount as an intangible asset in its books of account, did not add the same to the block of intangible assets for tax purposes, did not compute any Written

Hyderabad Ring Road Project Private Limited, India vs. ACIT, Circle

In the result Appeal of the assessee in ITA No

ITA 4090/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Mar 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Chinu Bhasin, AdvFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 143(3)

corresponding cross objection of assessee. 7. Grounds in CO and ITA of assessee are in respect of disallowance of depreciation @ 25% on intangible asset. With regards to the claim of depreciation, at the very outset, the ld. counsel for the assessee vehemently submitted that the instant issue is squarely covered ... assessee for design, construction, development, finance, operation and maintenance of eight lane access controlled express-way, have been capitalized under the head 'Intangible Asset' in the audited financial statement. It is also not in dispute that the assessee was to design, construct, develop, finance, operate, Page

ACIT, Circle - 10(1), Delhi vs. M/S Hyderabad Ring Road Project Private Limited, Delhi

In the result Appeal of the assessee in ITA No

ITA 3599/DEL/2025[2017-18]Status: DisposedITAT Delhi11 Mar 2026AY 2017-18

Bench: Ms. Madhumita Roy & Shri Naveen Chandra

For Appellant: Shri Chinu Bhasin, AdvFor Respondent: Shri Mahesh Kumar, CIT-DR
Section 143(3)

corresponding cross objection of assessee. 7. Grounds in CO and ITA of assessee are in respect of disallowance of depreciation @ 25% on intangible asset. With regards to the claim of depreciation, at the very outset, the ld. counsel for the assessee vehemently submitted that the instant issue is squarely covered ... assessee for design, construction, development, finance, operation and maintenance of eight lane access controlled express-way, have been capitalized under the head 'Intangible Asset' in the audited financial statement. It is also not in dispute that the assessee was to design, construct, develop, finance, operate, Page

M/S Sova, Panaji vs. Pr. Commissioner of Income Tax, Panaji

The appeal of the assessee is PARTLY ALLOWED in aforestated terms

ITA 24/PAN/2024[2018-19]Status: DisposedITAT Panaji10 Mar 2026AY 2018-19

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2018-19 M/S Sova Salgaocar Bhavan, Altinho, Panaji, Goa-403001. Pan: Aacfs8862Q . . . . . . . Appellant V/S Pr. Commissioner Of Income Tax, Panaji, Goa. . . . . . . . Respondent

For Appellant: Mr Sukhsagar Syal [‘Ld. AR’]For Respondent: Mr M Satish [‘Ld. DR’]
Section 143(2)Section 143(3)Section 253(1)Section 263Section 56

held the sum paid in the form of ‘stamp duty’ for renewal of mining lease as ‘capital in nature’ thus eligible for depreciation as intangible assets u/s 32 of the Act and ‘registration fees’ as revenue in nature thus deductible u/s 37(1) of the Act. Without contesting but placing ... separately as per OGE passed, and further increased by (ii) consequential claim for depreciation on stamp duty capitalisation as ‘license’ being an intangible asset be granted. In directing the Revenue to allow consequential depreciation on capitalisation of ‘stamp duty’ as ‘license’ an intangible asset we place our reliance

Asirvad Micro Finance Limited, Anna Salai vs. Deputy Commissioner of Income Tax, Corporate Circle -1(1), Chennai

The appeal of the assessee is partly allowed

ITA 1139/CHNY/2025[2015-16]Status: DisposedITAT Chennai10 Mar 2026AY 2015-16

Bench: Shri Aby T. Varkey & Ms. Padmavathy.Sआयकर अपील सं./Ita No.1139/Chny/2025 िनधा$रण वष$ /Assessment Year: 2015-16

For Appellant: Mr. P.R. Prasanna Varma, FCAFor Respondent: Mr. Bipin C.N., CIT
Section 250Section 56(2)(viib)

company to the satisfaction of the Assessing Officer, based on the value, on the date of issue of shares, of its assets, including intangible assets being goodwill, know-how, Asirvad Micro Finance Ltd. :- 6 -: patents, copyrights, trademarks, licences, franchises or any other business or commercial rights of similar nature, whichever

Asst. Commissioner of Income Tax, Mumbai vs. Reliance Retail Limited, Mumbai

In the result, the appeal filed by the Revenue is dismissed, whereas the appeal filed by the assessee is partly allowed

ITA 4244/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: SHRI SAKTIJIT DEY (Vice President), SHRI MAKARAND VASANT MAHADEOKAR (Accountant Member)

Section 135Section 143(3)Section 144BSection 14ASection 250Section 37(1)Section 80GSection 80JSection 92C

expenditure amounting to Rs. 105,90,92,717/- was claimed as revenue expenditure. The Assessing Officer held that the expenditure resulted in creation of intangible asset and enduring benefit to the business and accordingly treated the same as capital expenditure. After allowing depreciation, addition ... justified in treating the Capital expenditure incurred by the assessee company as Revenue expenditure although the assessee has incurred the expenses of an intangible asset under development and the same is developed for the enduring benefit of the business of the assessee company. 4. Whether on the facts and circumstances

Reliance Retail Limited, Mumbai vs. Assistant Commissioner of Income Tax Circle 8(1)(1), Mumbai

ITA 3510/MUM/2025[2019-20]Status: DisposedITAT Mumbai10 Mar 2026AY 2019-20

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar

Section 135Section 143(3)Section 144BSection 14ASection 250Section 37(1)Section 80GSection 80JSection 92C

expenditure amounting to Rs. 105,90,92,717/- was claimed as revenue expenditure. The Assessing Officer held that the expenditure resulted in creation of intangible asset and enduring benefit to the business and accordingly treated the same as capital expenditure. After allowing depreciation, addition ... justified in treating the Capital expenditure incurred by the assessee company as Revenue expenditure although the assessee has incurred the expenses of an intangible asset under development and the same is developed for the enduring benefit of the business of the assessee company. 4. Whether on the facts and circumstances

Deputy Commissioner of Income Tax, Central Circle 2(2), Chennai vs. Oasys Cybermatics Pvt Ltd, Chennai

In the result, the appeal filed by the Revenue is dismissed

ITA 3102/CHNY/2025[2016-17]Status: DisposedITAT Chennai09 Mar 2026AY 2016-17

Bench: MS. PADMAVATHY S (Accountant Member), SHRI MANU KUMAR GIRI (Judicial Member)

For Appellant: Mr. ARV Srinivasan, CIT for Mr. Bipin C. N., CITFor Respondent: Mr. Ravi Kannan &
Section 143(2)Section 143(3)Section 147Section 148Section 36(1)(va)Section 5(3)

proceeded with the reassessment and completed the reassessment u/s. 147 of the Act on 31.03.2022 by making the following disallowances: Disallowance of depreciation on intangible assets – Rs.8.93 crore  Disallowance on account of delayed remittance of employee  contribution to PF/ESI – Rs.0.52 crore 6. The Assessing Officer observed that the assessee ... claimed depreciation on intangible assets including goodwill arising out of amalgamation. According to the Assessing Officer, such claim was not allowable in the facts and circumstances of the case and accordingly a sum of Rs.8.93 crore was disallowed. Further, it was observed that the assessee had remitted employees’ contribution towards

Deputy Commissioner of Income Tax-2(2)(1), Mumbai, Aayakar Bhavan, Churchgate vs. Mumbai International Airport Limited, Mumbai

ITA 7035/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokar

Section 143(3)Section 14ASection 250Section 28Section 32(1)(ii)Section 35D

ITAT'S order for earlier years, without appreciating that the right to operate the airport under a 30-year concession is, not an ‘intangible asset' owned by the assessee but a deferred capital outlay to be amortised over the concession tenure? 2. Whether, on the facts and in the circumstances ... merely grants a concession right for operating the airport for a fixed tenure of 30 years and does not result in acquisition of an intangible asset owned by the assessee. It was therefore contended that the payment represents a capital outlay which ought to be amortised over the concession period

Mumbai International Airport Limited, Mumbai vs. Deputy Commissioner of Income Tax, Circle 2(2)(1), Mumbai

The appeal of the assessee is allowed for statistical purposes, whereas the appeal of the Revenue is dismissed

ITA 6692/MUM/2025[2014-15]Status: DisposedITAT Mumbai09 Mar 2026AY 2014-15

Bench: Shri Saktijit Dey & Shri Makarand V Mahadeokara.Y:2014-15 Mumbai International Vs. Dcit, Circle – 2(2)(1) Airport Ltd., Aayakar Bhavan, Mk Road 1St Floor, Terminal-1B, New Marine Lines, Mumbai – Chhatrpati Shivaji 400020. International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) A.Y:2014-15 Dcit, Circle – 2(2)(1) Vs. Mumbai International Aayakar Bhavan, Mk Road Airport Ltd., New Marine Lines, Mumbai – 1St Floor, Terminal-1B, 400020. Chhatrpati Shivaji International Airport, Santacruz (E), Mumbai – 400099. Pan/Gir No. Aaecm6285C (Applicant) (Respondent) Assessee By Shri Saurabha Soparkar Virtually Appeared Revenue By Shri Annavaram Kosuri, Sr. Ar Date Of Hearing 25.02.2026 Date Of Pronouncement 09.03.2026 आदेश / Order Per Makarand V Mahadeokar, Am: These Cross Appeals Are Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals) Under Section 250 Of The Mumbai International Airport Ltd., Mumbai Income-Tax Act, 1961 Dated 05.08.2025 In The Case Of The Assessee For Assessment Year 2014–15. The Assessment In The Present Case Was Originally Completed By The Assessing Officer Under Section 143(3) Of The Act Vide Order Dated 30.12.2017. Since The Issues Involved In The Appeals Of The Revenue As Well As The Assessee Arise Out Of The Same Appellate Order Of The Ld. Cit(A), These Appeals Were Heard Together & Are Being Disposed Of By Way Of This Common Order For The Sake Of Convenience & Brevity.

Section 143(3)Section 14ASection 250Section 28Section 32(1)(ii)Section 35D

ITAT‟S order for earlier years, without appreciating that the right to operate the airport under a 30-year concession is, not an „intangible asset‟ owned by the assessee but a deferred capital outlay to be amortised over the concession tenure? 2. Whether, on the facts and in the circumstances ... merely grants a concession right for operating the airport for a fixed tenure of 30 years and does not result in acquisition of an intangible asset owned by the assessee. It was therefore Mumbai International Airport Ltd., Mumbai contended that the payment represents a capital outlay which ought

Ascentech Engineering Solutions Private Limited, Hyderabad vs. DCIT, Circle 1(1), Hyderabad

ITA 1686/HYD/2025[2017-18]Status: HeardITAT Hyderabad06 Mar 2026AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita.No.1686/Hyd/2025

For Appellant: MS Sree Lekha, AdvocateFor Respondent: Sri Mathivanan S A, Sr. AR
Section 56(2)(vii)Section 56(2)(viib)

IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A' Bench, Hyderabad BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MADHUSUDAN

ACIT CC 4 3, Mumbai vs. Maersk Line India Private Limited, Mumbai

ITA 6166/MUM/2025[2020-21]Status: DisposedITAT Mumbai05 Mar 2026AY 2020-21

Bench: Shri Vikram Singh Yadav & Shri Sandeep Singh Karhail

For Appellant: Shri Manish Kant, CAFor Respondent: Shri Virabhadra Mahajan, (Sr. DR)
Section 135Section 143(2)Section 206ASection 250Section 40Section 80G

repairs and insurance ofplant, machinery and furniture. • Section 32 provides for depreciation on tangible assets like building, machinery, plant, furniture and also on intangible assets like know-how, patents, trademarks, licenses. • Section 33 allows development rebate on machinery, plantsand ships. • Section 34 statesconditions for depreciation and development rebate. • Section

M/S R. S. Shetye & Bros, Panaji vs. Assistant Commissioner of Income Tax, Circle -1(1), Panaji

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

ITA 37/PAN/2023[2016-17]Status: DisposedITAT Panaji27 Feb 2026AY 2016-17

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.37/Pan/2023 (A.Y.2016-17) R.S.Shetye & Bros, Vs Acit 1(1), Flat.No.14, 1 St Floor, Aaykar Bhavan, . Trionara Apartments, Edc, Patto, New Muncipal Market, Panjim Panaji- Goa-403001. Goa-403001. Pan .No.Aabfr9785N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 3

section 2(11) of the Act which defines the term 'block of assets' means a fixed assets classified into (a) tangible and (b) intangible assets. The intangible assets are know-how, patents, copyrights, trademarks, licences, franchises or any other business or commercial rights of similar nature. Perhaps as a safeguard ... measure Explanation 3 to section 32(1) is pari-materia of section 2(11) to cover both tangible and intangible assets for depreciation. 37. Section 32 of the Act on the other hand, allows a deduction for depreciation on tangible (buildings, furniture & fixture and Plant & machinery) as well

ACIT Central Circle 2(3), Ahmedabad vs. Intas Pharmaceuticals Limited, Ahmedabad

In the result, the appeal of the Revenue is dismissed

ITA 1842/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

Section 250

Gujarat High Court in PCIT v. Zydus Wellness Ltd. [(2017) 87 taxmann.com 82], the CIT(A) held that goodwill qualifies as an intangible asset under Explanation 3(b) to section 32(1) and is eligible for depreciation. The CIT(A) also noted that the SLP filed by the Department against ... considered view that such an observation, even if factually correct, does not in itself negate the existence or allowability of goodwill as an intangible asset. It is now well settled in law that the term “goodwill” is not limited to a customer list or an externally acquired brand. It encompasses

Equifax Credit Information Services Pvt Ltd, Mumbai vs. Income Tax Officer WD-9(2)(1), Mumbai

In the result, the appeal for A

ITA 5324/MUM/2025[2011-12]Status: DisposedITAT Mumbai24 Feb 2026AY 2011-12
Section 143(1)Section 143(3)Section 254Section 40A(2)(b)Section 68

comprising professional fees, hardware ®& _ software maintenance, hosting charges, communication charges, royalty (if any), and two significant capitalised components, namely Intangible Asset — CBS Software (capitalised) and Intangible Asset - CBS Software closing WIP (capitalised). The assessee has further demonstrated that the capitalised amount aggregated to Rs. 6,03,95,535/-. Thereafter

Equifax Credit Information Services Pvt Ltd, Mumbai vs. Income Tax Officer WD-9(2)(1), Mumbai

In the result, the appeal for A

ITA 5323/MUM/2025[2012-13]Status: DisposedITAT Mumbai24 Feb 2026AY 2012-13
Section 143(1)Section 143(3)Section 254Section 40A(2)(b)Section 68

comprising professional fees, hardware ®& _ software maintenance, hosting charges, communication charges, royalty (if any), and two significant capitalised components, namely Intangible Asset — CBS Software (capitalised) and Intangible Asset - CBS Software closing WIP (capitalised). The assessee has further demonstrated that the capitalised amount aggregated to Rs. 6,03,95,535/-. Thereafter

M/S. Ntt Data Global Services Private Limited, Bangalore vs. The Joint Commissioner of Income Tax, Special Range- 5, Bangalore

ITA 2533/BANG/2019[2015-16]Status: DisposedITAT Bangalore23 Feb 2026AY 2015-16
For Appellant: Shri Chavali NarayanFor Respondent: Dr. Divya K. J
Section 133(6)Section 143(3)Section 144C(13)Section 144C(5)

under: "H.3 We note that primarily the segmental details are not available in respect of the various services rendered by this comparable. Further the intangible asset has been valued at Rs.117 crs. thereby indicating the ownership of the software developed by the company. This also indicates the high brand value ... Rs.262.84 million, was mainly on account of acquisition of various IPs during the year and the same is shown in the intangible Asset Schedule of the consolidated financial statement at page 115 as under: Intangible assets of Group 2012-13) 12.2 Intangible assets Software Acquired contractual rights Total Gross block

Rubber King Tyre Private Limited, Ahmedabad, Gujarat vs. DCIT, 3(1)(2), Ahmedabad, Gujarat

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 145/AHD/2026[2017-18]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2017-18

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years: 2017-18

Section 143(3)Section 32Section 32(1)Section 43(1)Section 43(6)

following the binding judgments including those of Honble Apex Court and Gujarat High Court on the eligibility of depreciation on intangible assets. The appellant prays that the depreciation claim of Rs. 3.31.62.509/- be directed to be granted. 8. The learned Commissioner of Income tax (Appeals) National Faceless Appeal Centre (NFAC ... NFAC), Delhi has erred in confirming the action of the Assessing Officer in making addition of Rs. 1,32,28,661/- being depreciation on intangible assets which is not permissible while computing Book Profit under section 115JB of the IT Act. 10. The learned Commissioner of Income tax (Appeals) National

Franklin Templeton International Services (India) P.Ltd, Mumbai vs. DCIT Cir 3(1), Mumbai

In the result, appeals filed by the assessee stands partly allowed

ITA 2047/MUM/2014[2009-10]Status: DisposedITAT Mumbai20 Feb 2026AY 2009-10

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

Section 133(6)Section 92D

effectively. The assets maintained by FTIS include computers, office equipment, furniture and fixtures and human capital. FTIS does not own any valuable non-routine intangible assets. Data Processing Service Segment It is submitted that the assessee seeking inclusion of following comparables: • NIIT Smartserve Ltd. • KPIT Cummins Global Business Solutions ... light of records placed before us. 23.2 This Tribunal has been consistently taking the view that companies having huge brand value as well as intangible assets cannot be compared with a captive service provider. We draw support from the decision of Hon’ble Delhi High Court in case of Agnity

Messe Frankfurt Trade Fairs India Private Limited, Mumbai vs. Deputy Commissioner of Income Tax 2(2)(1), Income Tax Department, Mumbai

ITA 6680/MUM/2025[2018-2019]Status: DisposedITAT Mumbai19 Feb 2026AY 2018-2019

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokar1. Ita No. 6498/Mum/2025 (Assessment Year: 2018-19) & 2. Ita No. 6680/Mum/2025 (Assessment Year: 2018-19) Messe Frankfurt Trade Dcit – 2(2)(1), Fairs India Private Income Tax Limited, Vs. Department, 501, 5Th Floor, Gala Mumbai-400 020 Impecca, Mumbai, Chakala Midc S.O, Mumbai-400 093. Pan/Gir No. Aabcm0696G (Applicant) (Respondent) Assessee By Shri Ninad Patade, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 18.02.2026 Date Of Pronouncement 19.02.2026

Section 143(3)Section 250Section 253(5)Section 270ASection 80G

Director. In the affidavit, it is stated that after the learned CIT(A) partly allowed relief by deleting the disallowance of depreciation on intangible assets and sustained only the disallowance of deduction under section 80G of Rs. 9,90,000/-, the assessee, considering the quantum of tax involved and with