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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

Jt. Cti (OSD), Circle-3(1)(1), Ahmedabad vs. M/S. Nirma Limited, Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 791/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 2(24)(x)Section 234BSection 271

Disallowance of claim of Sales Tax subsidy as capital receipts of Rs.81.51.84,216/-. 2. Disallowance of excess claim of depreciation on intangible assets for Rs.7,31,74,359/-. 3. Disallowance of product registration expenses of Rs.35,35,877/-. 4. Addition on account of benchmarking of loan u/s 92CA Rs.38 ... facts in deleting the disallowance of Rs.5,48,80,769/- made by A.O. on account of excess claim of depreciation on intangible assets. 3. The Ld.CIT(A) has erred in law and on facts in deleting the addition of Rs.14,81,249/- made by A.O, on account of product registration

Nirma Limited, Ahmedabad vs. DCIT, Circle-3(1)(1), Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 516/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 2(24)(x)Section 234BSection 271

Disallowance of claim of Sales Tax subsidy as capital receipts of Rs.81.51.84,216/-. 2. Disallowance of excess claim of depreciation on intangible assets for Rs.7,31,74,359/-. 3. Disallowance of product registration expenses of Rs.35,35,877/-. 4. Addition on account of benchmarking of loan u/s 92CA Rs.38 ... facts in deleting the disallowance of Rs.5,48,80,769/- made by A.O. on account of excess claim of depreciation on intangible assets. 3. The Ld.CIT(A) has erred in law and on facts in deleting the addition of Rs.14,81,249/- made by A.O, on account of product registration

The DCIT, Cir-3(1)(1), Ahmedabad vs. M/S. Nirma Limited, Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 2224/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 2(24)(x)Section 234BSection 271

Disallowance of claim of Sales Tax subsidy as capital receipts of Rs.81.51.84,216/-. 2. Disallowance of excess claim of depreciation on intangible assets for Rs.7,31,74,359/-. 3. Disallowance of product registration expenses of Rs.35,35,877/-. 4. Addition on account of benchmarking of loan u/s 92CA Rs.38 ... facts in deleting the disallowance of Rs.5,48,80,769/- made by A.O. on account of excess claim of depreciation on intangible assets. 3. The Ld.CIT(A) has erred in law and on facts in deleting the addition of Rs.14,81,249/- made by A.O, on account of product registration

M/S. Nirma Limited, Ahmedabad vs. The DCIT, Circle-3(1)(1), Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 2008/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 2(24)(x)Section 234BSection 271

Disallowance of claim of Sales Tax subsidy as capital receipts of Rs.81.51.84,216/-. 2. Disallowance of excess claim of depreciation on intangible assets for Rs.7,31,74,359/-. 3. Disallowance of product registration expenses of Rs.35,35,877/-. 4. Addition on account of benchmarking of loan u/s 92CA Rs.38 ... facts in deleting the disallowance of Rs.5,48,80,769/- made by A.O. on account of excess claim of depreciation on intangible assets. 3. The Ld.CIT(A) has erred in law and on facts in deleting the addition of Rs.14,81,249/- made by A.O, on account of product registration

M/S. Nirma Limited, Ahmedabad vs. The DCIT, Circle-3(1)(1), Ahmedabad

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 2007/AHD/2017[2012-13]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2012-13

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 2(24)(x)Section 234BSection 271

Disallowance of claim of Sales Tax subsidy as capital receipts of Rs.81.51.84,216/-. 2. Disallowance of excess claim of depreciation on intangible assets for Rs.7,31,74,359/-. 3. Disallowance of product registration expenses of Rs.35,35,877/-. 4. Addition on account of benchmarking of loan u/s 92CA Rs.38 ... facts in deleting the disallowance of Rs.5,48,80,769/- made by A.O. on account of excess claim of depreciation on intangible assets. 3. The Ld.CIT(A) has erred in law and on facts in deleting the addition of Rs.14,81,249/- made by A.O, on account of product registration

Invesco(India) Private Limited, Hyderabad vs. DCIT, Circle -2 (1), Hyderabad

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

ITA 111/HYD/2022[2017-18]Status: DisposedITAT Hyderabad30 Jun 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA, Sriram SeshadriFor Respondent: Shri B Bala Krishna, CIT-DR
Section 143(3)Section 144C(5)

company is not on commercial or business exigencies, but, it is a business combination in the intra group so as to create an ordinary intangible asset in the form of huge goodwill and, thereby, claiming depreciation on it to lower the tax liability of the assessee-company. The creation ... artificial intangible asset by the assessee company in the intra-group companies without proper justification is, in the nature of employing a device of avoidance of tax. Therefore, the Assessing Officer rejected the explanation of assessee and disallowed depreciation claimed on ‘goodwill’ of Rs.141,23,01,606/- and made addition

Myvishwa Technologies Pvt. Ltd., Pune vs. Dycit Circle-7, Pune

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

ITA 942/PUN/2025[2018-19]Status: DisposedITAT Pune27 Jun 2025AY 2018-19

Bench: Ms.Astha Chandra, Judicialmember & Dr.Dipak P. Ripoteआयकर अपील सं. / Ita No.942/Pun/2025 िनधा"रण वष" / Assessment Year: 2018-19 Myvishwa Technologies Pvt. V The Dy.Commissioner Of Ltd., S Income Tax, Circle-7, Flat No.16, Sawali, Pan Mala, Pune. Off Sinhgad Road, Pune- 411030. Maharashtra. Pan: Aafcm9656E Appellant/ Assessee Respondent / Revenue Assessee By Shri Mahavir Jain – Ar Revenue By Shri Rajesh Haladkar – Addl.Cit(Dr) Date Of Hearing 26/06/2025 Date Of Pronouncement 27/06/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Is Directed Against The Order Of Ld.Commissioner Of Income Tax(Appeals)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961, Dated 07.02.2025 Emanating From The Assessment Order Passed U/S.143(3) Of The Income Tax Act, 1961, For A.Y.2018-19 Dated 24.02.2021. The Assessee Has Raised Following Grounds Of Appeal :

Section 143(3)Section 250Section 32Section 32(1)

against returned income of Rs. 16,25,840/- there by confirming the disallowance of Rs. 32,04,890/- being amount depreciation claimed on Intangible assets. 21 The Ld. CIT(A)/NFAC has erred in disposing off the case ex-parte without appreciating that the appellant has requested for granting additional ... /NFAC erred in upholding the disallowance of depreciation of Rs. 32,04,890/- claimed @ 12.5% (1/2 of 25%) on 'Intangible Asset' u/s. 32 of the Income Tax Act without appreciating that the cost capitalized as Intangible assets in the books was covered as "Intangible Assets" as defined explanation

Freudenberg Gala Household Product Private Limited, Mumbai vs. Income Tax Officer Circle 15(1)(1), Mumbai

In the result, appeal of the assessee is partly allowed

ITA 1124/MUM/2025[2012-13]Status: DisposedITAT Mumbai27 Jun 2025AY 2012-13

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Sandeep Singh Karhail, Hon'Ble

For Appellant: Ms. Ashwini Bhide/Mr. Nilesh Dhedia, A/RsFor Respondent: Ms. Kavita P. Kaushik, Sr. D/R

Intangible assets Goodwill 12,491,600 12,491,600 2,063,681 1,249,160 3,312,841 9,178,759 10,427,919 Trade marks, copy rights and patents

Assistant Commissioner of Income Tax, Circle 1, Jodhpur vs. Suncity Metals and Tubes Pvt. Ltd., Jodhpur

In the result, the revenue appeal is dismissed

ITA 267/JODH/2024[2020-21]Status: DisposedITAT Jodhpur24 Jun 2025AY 2020-21

Bench: Dr. Mitha Lal Meena, HonʼBle & Dr. S. Seethalakshmi, Hon'Ble

Section 32(1)Section 32(1)(ii)Section 43(1)Section 55(2)(a)

Income Tax, Range- 12, Bangalore (2016) and held that the ruling of SC is limited to issue whether goodwill falls in the category of intangible assets. The ITAT held that judgment of Hon'ble SC does not override the provisions of 5th proviso to section 32(1), now 6th proviso ... with decision of honourable SC in Techno Shares and Stocks v CIT (2010) of the act i.e. not only nature and character of the intangible asset should we clearly established but it is to be established akin to any asset. 7. Whether the Id. CIT(A) is justified in facts

Roads and Bridges Development Corporation of Kerala Ltd, Ernakulam vs. The Assistant Commissioner of Income Tax, Corporate Circle 2(1), Kochi, Ernakulam

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

ITA 568/COCH/2023[A.Y 2011-12]Status: DisposedITAT Cochin24 Jun 2025

Bench: Shri Inturi Rama Rao, Am & Shri Prakash Chand Yadav, Jm Assessment Year: 2011-12 Roads & Bridges Development .......... Appellant Corporation Of Kerala Ltd. Preethi Building, M.V. Road, Palarivattom Ernakulam 682025 [Pan: Aabcr7841Q] Vs. Acit, Corporte Circles-2(1), Kochi .......... Respondent Appellant By: Smt. Remya S. Menon, Ca Respondent By: Shri Sundarasan S., Cit.Dr Date Of Hearing: 29.05.2025 Date Of Pronouncement: 24.06.2025 O R D E R Per: Inturi Rama Rao, Am This Appeal Filed By The Assessee Is Directed Against The Order Of The National Faceless Appeal Centre, Delhi [Cit(A)] Dated 17.03.2023 For Assessment Year (Ay) 2011-12. 2. Brief Facts Of The Case Are That The Appellant Is A Company Which Is A Wholly Owned By Government Of Kerala Undertaking. It Is Engaged In The Business Of Construction, Development, Operation & Maintenance Of Railway Over Bridges, Highway Projects, Etc. The 2 Roads & Bridges Development Corporation Of Kerala Ltd. Original Return Of Income For Ay 2011-12 Was Filed On 28.09.2011 Declaring Loss Of Rs. 9,65,43,016/-. The Same Was Revised On 07.01.2013 At A Loss Of Rs. 5,11,71,331/-. Against The Said Return Of Income, The Assessment Was Completed By The Acit, Corporate Circle 2(1), Kochi Vide Order Dated 30.03.2014 At Total Income Of Rs.2,10,68,827/- Before Set Off Of Brought Forward Loss. Ultimately The Income Was Assessed At Nil Income. Subsequently, The Ao Issued A Notice U/S. 148 Of The Income Tax Act, 1961 (The Act) On 10.04.2015 For The Reason That Income Escaped Assessment To Tax For Following Reasons: -

For Appellant: Smt. Remya S. Menon, CAFor Respondent: Shri Sundarasan S., CIT.DR
Section 139(4)Section 143Section 148

While doing so, the AO denied set off of loss allowed in the original assessment of Rs. 3,80,22,354/-, disallowed depreciation on intangible assets of Rs. 1,60,79,904/- and made addition on interest of Rs. 36,51,373/-. 3 Roads and Bridges Development Corporation of Kerala ... judgement of the Hon'ble Kerala High Court in assessee’s own case. However, confirmed the addition on account of disallowance of depreciation on intangible assets following the decision of the Hon'ble Rajasthan High Court in the case of Golcha Properties

Shree Cement Limited, Bangur Nagar vs. ACIT, Central Circle, Ajmer

In the result, the appeal of the assessee - appellant in ITA No

ITA 1517/JPR/2024[2019-2020]Status: DisposedITAT Jaipur24 Jun 2025AY 2019-2020

Bench: DR. S. SEETHALAKSHMI (Judicial Member)

For Appellant: Shri Dilip B. Desai, FCAFor Respondent: Shri Arvind Kumar, CIT-DR
Section 115JSection 143(1)Section 254Section 36(1)(va)Section 80Section 801A

such facts, courts have held that such rights acquired by the assessee which is used for the purpose of its business is an intangible asset in the nature of business or commercial right. Such intangible assets being "business or commercial right" is entitled to depreciation ... additional ground no. 1 raised by the assessee is allowed" Thus, the Hon'ble ITAT held that such intangible assets being "business or commercial right" was entitled to depreciation u/s 32(1)(ii) of the Act, hence, directed the AO to grant depreciation @25% on such leasehold rights in accordance

ACIT, Circle Ltu-1, Chennai vs. Carborundum Universal Limited, Chennai

In the result, the appeals filed by Revenue in ITA Nos

ITA 140/CHNY/2025[2014-15]Status: DisposedITAT Chennai23 Jun 2025AY 2014-15

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपीलसं./Ita Nos. 139, 140 & 117/Chny/2025 ("नधा"रण वष" / Assessment Years: 2013-14, 2014-15 & 2018-19)

For Appellant: Ms. Anitha, Addl. CITFor Respondent: Shri Vikram Vijayaraghavan
Section 32(1)(iia)Section 40

allowed. (ii) Disallowance of depreciation on brand value:- 4.6 The sixth ground of appeal relates to disallowance of depreciation claimed on the Intangible assets acquired along with Jabalpur unit Rs.83,057/-. The appellant has filed the following written submissions on this issue. The same is reproduced below: During the Assessment ... Year 2007-08, the assessee Company acquired two units at Jabalpur on going concern basis for a consideration of Rs.320 lakhs, which includes the intangible asset towards Brand amounting to Rs.16 lakhs. The assessee company claimed depreciation at the rate of 25% on the intangible asset of Brand value

Assistant Commissioner of Income Tax, Circle Ltu-1, Chennai vs. Carborundum Universal Limited, Chennai

In the result, the appeals filed by Revenue in ITA Nos

ITA 139/CHNY/2025[2013-14]Status: DisposedITAT Chennai23 Jun 2025AY 2013-14

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपीलसं./Ita Nos. 139, 140 & 117/Chny/2025 ("नधा"रण वष" / Assessment Years: 2013-14, 2014-15 & 2018-19)

For Appellant: Ms. Anitha, Addl. CITFor Respondent: Shri Vikram Vijayaraghavan
Section 32(1)(iia)Section 40

allowed. (ii) Disallowance of depreciation on brand value:- 4.6 The sixth ground of appeal relates to disallowance of depreciation claimed on the Intangible assets acquired along with Jabalpur unit Rs.83,057/-. The appellant has filed the following written submissions on this issue. The same is reproduced below: During the Assessment ... Year 2007-08, the assessee Company acquired two units at Jabalpur on going concern basis for a consideration of Rs.320 lakhs, which includes the intangible asset towards Brand amounting to Rs.16 lakhs. The assessee company claimed depreciation at the rate of 25% on the intangible asset of Brand value

ACIT, Ltu Circle 1 Chennai, Chennai vs. Carborundum Universal Limited, Chennai

In the result, the appeals filed by Revenue in ITA Nos

ITA 117/CHNY/2025[2018-19]Status: DisposedITAT Chennai23 Jun 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपीलसं./Ita Nos. 139, 140 & 117/Chny/2025 ("नधा"रण वष" / Assessment Years: 2013-14, 2014-15 & 2018-19)

For Appellant: Ms. Anitha, Addl. CITFor Respondent: Shri Vikram Vijayaraghavan
Section 32(1)(iia)Section 40

allowed. (ii) Disallowance of depreciation on brand value:- 4.6 The sixth ground of appeal relates to disallowance of depreciation claimed on the Intangible assets acquired along with Jabalpur unit Rs.83,057/-. The appellant has filed the following written submissions on this issue. The same is reproduced below: During the Assessment ... Year 2007-08, the assessee Company acquired two units at Jabalpur on going concern basis for a consideration of Rs.320 lakhs, which includes the intangible asset towards Brand amounting to Rs.16 lakhs. The assessee company claimed depreciation at the rate of 25% on the intangible asset of Brand value

Livlong Insurance Brokers Limited, Mumbai vs. PCIT -4, Mumbai

ITA 2864/MUM/2025[2020-21]Status: DisposedITAT Mumbai17 Jun 2025AY 2020-21

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Pritesh Mehta,ARFor Respondent: Shri Aditya Rai, (Sr. DR)
Section 135Section 143(3)Section 263Section 37Section 80G

order would make it erroneous and prejudicial to the interest of Revenue. Accordingly, the Ld.PCIT considered nothing about the claim of depreciation on the intangible assets in the impugned assessment orders rendered erroneous and prejudicial to the interest of revenue on this count also. In support of this proposition ... restored them to the file of the AO for the limited purpose of conducting enquiry with regard to the claim of depreciation on intangible assets and taking decision as per law. The assessee aggrieved by the revision orders so passed by the Ld.PCIT in both the years under consideration

Agricom Foods Private Limited, Mumbai vs. DCIT, Central Circle 4(4), Mumbai

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

ITA 2740/MUM/2025[2017-18]Status: DisposedITAT Mumbai16 Jun 2025AY 2017-18

Bench: Shri Sandeep Gosain, () & Shri Prabhash Shankar, ()

Section 143(1)Section 143(2)Section 153ASection 154Section 250

Mumbai has erred as under: 1. In holding that the Appellant was not entitled to claim depreciation of Rs. 7,55,00,000 on Intangible assets - whereas there was no depreciation that was claimed at all during the year. Hence, he erred in adjudicating the issue of allowability of Depreciation ... running undertaking on a lump sum price basis from an unrelated entity and purchase consideration was thereafter allocated amongst tangible assets and intangible assets largely being licenses, permits and approvals.” 2. The brief facts of the case are that the assessee is a partnership Firm. The assessee had filed

Tata Cummins Private Limited, Pune vs. The DCIT Circle-1-Jamshedpur and the Assessment Unit, Income-Tax Department, NFAC, Delhi, Jamshedpur

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

ITA 430/RAN/2024[2021-22]Status: DisposedITAT Ranchi12 Jun 2025AY 2021-22

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaytata Cummins Private Limited, D.C.I.T., Cummins India Office, Tower-A, 7Th Circle-1, Vs. Floor, Survey No. 21, Balewadi, Pune, Jamshedpur. Maharashtra. Pan No. Aaact 6353 L Appellant/ Assessee Respondent/ Revenue

Clause (ii) of the said Explanation reads as follows- 4 Tata Cummins Vs DCIT (ii) the expression intangible property" shall include— (b) technology related intangible assets, such as, process patents, patent applications, technical documentation such as laboratory notebooks, technical know-how .................... 9.14 At the very outset, it would be seen ... sale, transfer, lease or use of intangible property has been classified as an international transaction. Intangible property has been defined to include technology related intangible assets such as process patents, technical know-how, etc. Thus, where two AEs engage in a transaction, which involves the purchase, sale, transfer lease

DCIT., Circle-13(1), Hyderabad vs. The Singareni Collieries Company Limited, Kothagudem

In the result, assessee’s appeals for the A

ITA 308/HYD/2024[AY-2020-2]Status: DisposedITAT Hyderabad12 Jun 2025

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Shri B Balakrishna, CIT (DR)
Section 40A(9)

furniture, being tangible assets;(ii)know-how, patents, copyrights, trademarks, licenses, franchises or any other business or commercial rights of similar nature, being intangible assets acquired on or after the 1st day of April, 1998, [not being goodwill of a business or profession]owned, wholly or partly, by the assessee ... furniture, being tangible assets or know-how, patents, copyrights, trademarks, licenses, franchises or any other business or commercial rights of similar nature, being intangible assets allowable to the predecessor and the successor in the case of succession referred to in clause (xiii), clause (xiiib) and clause (xiv) of section

DCIT, Circle-13(1), Hyderabad vs. The Singareni Collieries Company Limited, Kothagudem

In the result, assessee’s appeals for the A

ITA 301/HYD/2024[2016-17]Status: DisposedITAT Hyderabad12 Jun 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V.Anil Kumar, Advocate
Section 194Section 32ASection 37Section 40Section 40A(9)

furniture, being tangible assets;(ii)know-how, patents, copyrights, trademarks, licenses, franchises or any other business or commercial rights of similar nature, being intangible assets acquired on or after the 1st day of April, 1998, [not being goodwill of a business or professionjowned, wholly or partly, by the assessee ... furniture, being tangible assets or know-how, patents, copyrights, trademarks, licenses, franchises or any other business or commercial rights of similar nature, being intangible assets allowable to the predecessor and the successor in the case of succession referred to in clause (xiii), clause (xiiib) and clause (xiv) of section

DCIT., Circle-13(1), Hyderabad vs. The Singareni Collieries Company Ltd, Kothagudem

In the result, assessee’s appeals for the A

ITA 300/HYD/2024[2015--16]Status: DisposedITAT Hyderabad12 Jun 2025

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G.आ.अपी.सं /Ita Nos.283, 284 & 286/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Singareni Collieries Vs. Acit, Circle – 1 Company Limited Khammam & Kothagudem Acit, Circle 13(1) Pan:Aaact8873F Hyderabad & आ.अपी.सं /Ita Nos.300, 301 & 308/Hyd/2024 (िनधा"रण वष"/Assessment Years: 2015-16, 2016-17 & 2020-21) Vs. Singareni Collieries Dy. Cit, Circle 13(1) Company Limited Hyderabad Kothagudem Pan:Aaact8873F (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri M.V.Anil Kumar, Advocate राज" व "ारा/Revenue By:: Shri B Balakrishna, Cit (Dr) सुनवाई की तारीख/Date Of Hearing: 10/06/2025 घोषणा की तारीख/Pronouncement: 12/06/2025 आदेश/Order Per Bench: These 3 Sets Of Cross Appeals Filed By The Assessee As Well As The Revenue Are Directed Against The 3 Separate Orders All Dated 30/01/2024 Of The Learned Cit (A)-Nfac Delhi, For The A.Ys 2015-16, 2016-17 & 2020-21 Respectively. The Assessee As Well As The Revenue Have Raised The Following Grounds Of Appeals For 3 A.Ys:

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Shri B Balakrishna, CIT (DR)
Section 40A(9)

furniture, being tangible assets;(ii)know-how, patents, copyrights, trademarks, licenses, franchises or any other business or commercial rights of similar nature, being intangible assets acquired on or after the 1st day of April, 1998, [not being goodwill of a business or profession]owned, wholly or partly, by the assessee ... furniture, being tangible assets or know-how, patents, copyrights, trademarks, licenses, franchises or any other business or commercial rights of similar nature, being intangible assets allowable to the predecessor and the successor in the case of succession referred to in clause (xiii), clause (xiiib) and clause (xiv) of section