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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

ACIT-3(4), Mumbai vs. Reliance Industries Limited, Mumbai

In the result, the appeal of the Revenue is dismissed whereas the appeal of the assessee is allowed

ITA 2898/MUM/2024[2016-17]Status: DisposedITAT Mumbai22 Nov 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2016-17 Reliance Industries Ltd., Dy. Cit Circle 3(4), 3Rd Floor, Maker Chamber Iv 222 Room No. 559, Aayakar Bhavan, Nariman Point, Vs. Maharshi Karve Road, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent Assessment Year: 2016-17 Acit-3(4), Reliance Industries Ltd., Room No. 481(2), 4Th Floor, 3Rd Floor, Maker Chamber Iv Aayakar Bhavan, N.M. Road, Vs. Nariman Point, New Marine Lines, Mumbai-400021. Mumbai-400020. Pan No. Aaacr 5055 K Appellant Respondent

For Respondent: Mr. Madhur Agrawal
Section 14ASection 271(1)(c)Section 32A

During the assessment proceedings, the appellant had submitted that the appellant claimed depreciation u/s.32 in respect of KGD6 block considering the assets acquired as intangible assets and the depreciation was claimed@ 25%. The appellant explained that that the appellant acquired participating interest in KGD6 block by executing production sharing contract ... relation to exploration and drilling activity till 01.05.2009, i.e. date of commercial production, got accumulated year after year. The same was treated as intangible asset and the depreciation was claimed @ 25%. During the FY.2015-16, i.e. AY. 2016-17, depreciation on KGD6 block was computed at Rs.2164

Reliance Industries Limited, Mumbai vs. Deputy Commissioner of Income Tax -Circle 3(4), Mumbai

ITA 2767/MUM/2024[2016-17]Status: DisposedITAT Mumbai22 Nov 2024AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Appellant: Mr. Madhur AgrawalFor Respondent: Ms. Sanyogita Nagpal, CIT-DR
Section 14ASection 271(1)(c)Section 32A

During the assessment proceedings, the appellant had submitted that the appellant claimed depreciation u/s.32 in respect of KGD6 block considering the assets acquired as intangible assets and the depreciation was claimed @ 25%. The appellant explained that that the appellant acquired participating interest in KGD6 block by executing production sharing contract ... relation to exploration and drilling activity till 01.05.2009, i.e. date of commercial production, got accumulated year after year. The same was treated as intangible asset and the depreciation was claimed @ 25%. During the FY.2015-16, i.e. AY. 2016-17, depreciation on KGD6 block was computed at Rs.2164

Parasmani Gems Pvt. Ltd., Ahmedabad vs. The DCIT, Cir-3(1)(1), Ahmedabad

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

ITA 2263/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad21 Nov 2024AY 2013-14

Bench: Shri T.R. Senthil Kumar & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 2263/Ahd/2017 ("नधा"रण वष" / Assessment Year : 2013-14) बनाम/ Parasmani Gems Pvt. Ltd. The D.C.I.T. 2, Supan Complex, Nr. Circle 3(1)(1), Vs. Dharnidhar Derasar, Paldi, Ahmedabad Ahmedabad, Gujarat - 380006 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aadcp6337M (Appellant) .. (Respondent) अपीलाथ" ओर से /Appellant By : Shri Mehul K Patel, Ar ""यथ" क" ओर से/Respondent By : Shri Rignesh Das, Sr. Dr Date Of Hearing 23/10/2024 21/11/2024 Date Of Pronouncement

For Appellant: Shri Mehul K Patel, ARFor Respondent: Shri Rignesh Das, Sr. DR
Section 154Section 234ASection 56(2)(viib)

substantiated by the company to the satisfaction of the Assessing Officer, based on the value of its assets, including intangible assets, being goodwill, know-how, patents, copyrights, trademarks, licences, franchises or any other business or commercial rights of similar nature. This amendment will take effect from 1st April ... 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, patents, copyrights, trademarks, licences, franchises or any other business or commercial rights of similar nature, whichever is higher; 16. The Explanation

Max Hospitals and Allied Services Limited, Mumbai vs. Principal Commissioner of Income Tax Mumbai -3, Mumbai

In the result the appeal filed by the assessee stands dismissed

ITA 2907/MUM/2024[2018-19]Status: DisposedITAT Mumbai21 Nov 2024AY 2018-19

Bench: Smt. Beena Pillai & Smt Renu Jauhriassessment Year: 2018-19 Max Hospitals & Principal Allied Services Commissioner Of 401, 4Th Floor, Income Tax Mumbai- 3 Man Excellenza, Room No.612, Vs. S. V. Road, 6Th Floor, Vile Parle (W.), Aayakar Bhavan, Mumbai- 400056 Maharishi Karve Road, Pan: Aagcr9198D Mumbai- 400020. Appellant : Respondent

For Appellant: RespondentFor Respondent: Ms. Sanyogia Nagpal (CIT-DR)
Section 143(3)Section 14ASection 263Section 56(2)(viib)

r.w.s. 144B of the act was passed on 07/06/2021, determining total loss of Rs. 3,31,36,890/- after making addition of depreciation on intangible assets at Rs.2,63,67,188/- and disallowance made u/s. 14A of Rs. 7,35,020/-. Subsequently the case was selected for review ... determining total loss at Rs.3,31,36,890/-, after making addition of Depreciation on Max Hospitals and Allied Services; A. Y.2018-19 intangible Assets of Rs.2,63,67,188/- and Rs.7,35,020/- on account of 'Disallowance u/s 14A of the Act. 3. On perusal of the assessment records

The Dy. Commissioner of Income Tax Circle-4(1)(1), Ahmedabad vs. Suzlon Energy Ltd., Ahmedabad

In the result the Ground Nos

ITA 303/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

value of assets of the transferor companies and the value of shares issued. It has accounted for the goodwill arising out of amalgamation as intangible asset for Rs. 503.72 Crore, Rs 535.51 Crore and Rs 20.57 Crore in case of SWIL, SEBL and SEEL respectively. Thus, totalling ... further seen that the assessee has claimed depreciation of Rs. 132.48 Crores on the goodwill so created. Since, the intangible assets in the form of goodwill was owned/held by the amalgamating companies prior to the amalgamation at NIL cost only, after amalgamation, it has to be taken as NIL cost

The Dy. Commissioner of Income Tax Circle-4(1)(1), Ahmedabad vs. Suzlon Energy Ltd., Ahmedabad

In the result the Ground Nos

ITA 302/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

value of assets of the transferor companies and the value of shares issued. It has accounted for the goodwill arising out of amalgamation as intangible asset for Rs. 503.72 Crore, Rs 535.51 Crore and Rs 20.57 Crore in case of SWIL, SEBL and SEEL respectively. Thus, totalling ... further seen that the assessee has claimed depreciation of Rs. 132.48 Crores on the goodwill so created. Since, the intangible assets in the form of goodwill was owned/held by the amalgamating companies prior to the amalgamation at NIL cost only, after amalgamation, it has to be taken as NIL cost

Suzlon Energy Ltd., Ahmedabad vs. The Dy. Commissioner of Income Tax Circle-4(1)(1), Ahmedabad

In the result the Ground Nos

ITA 199/AHD/2023[2017-18]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2017-18

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

value of assets of the transferor companies and the value of shares issued. It has accounted for the goodwill arising out of amalgamation as intangible asset for Rs. 503.72 Crore, Rs 535.51 Crore and Rs 20.57 Crore in case of SWIL, SEBL and SEEL respectively. Thus, totalling ... further seen that the assessee has claimed depreciation of Rs. 132.48 Crores on the goodwill so created. Since, the intangible assets in the form of goodwill was owned/held by the amalgamating companies prior to the amalgamation at NIL cost only, after amalgamation, it has to be taken as NIL cost

Suzlon Energy Ltd., Ahmedabad vs. The Dy. Commissioner of Income Tax Circle-4(1)(1), Ahmedabad

In the result the Ground Nos

ITA 198/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad12 Nov 2024AY 2016-17

Bench: Shri T.R. SENTHIL KUMAR (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 115JSection 143(3)Section 14A

value of assets of the transferor companies and the value of shares issued. It has accounted for the goodwill arising out of amalgamation as intangible asset for Rs. 503.72 Crore, Rs 535.51 Crore and Rs 20.57 Crore in case of SWIL, SEBL and SEEL respectively. Thus, totalling ... further seen that the assessee has claimed depreciation of Rs. 132.48 Crores on the goodwill so created. Since, the intangible assets in the form of goodwill was owned/held by the amalgamating companies prior to the amalgamation at NIL cost only, after amalgamation, it has to be taken as NIL cost

Dy Commissioner of Income Tax CC-5(2), Mumbai vs. Jet Privilege Private Limited, Mumbai

In the result, the appeals for AY 2015-16 to 2018-19 & 2021-22 of the assessee, revenue, and Cross Objections of the assessee are allowed for statistical purposes

ITA 2325/MUM/2023[2021-22]Status: DisposedITAT Mumbai11 Nov 2024AY 2021-22

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

Section 32(1)

103/Mum/2023 Jet Privilege Pvt. Ltd. that during the year under consideration the assessee has made the following additions to the intangible assets against which the depreciation is claimed. 3. The AO also noticed that Note No. 27 of the financial statements filed by the assessee contains the following statement with ... Consequently, the goodwill of Rs.13,013,742,680 arising from said acquisition is disclosed in the balance sheet, under the heading Intangible assets.” 4. The assessee submitted before the AO that the assessee has acquired Jet Privilege Frequent Flyer Program (JPFFP) from M/s Jet Airways India Ltd. under slum sale

Jet Privilege Private Limited, Mumbai vs. Dy Commissioner of Income Tax CC-5(2), Mumbai

In the result, the appeals for AY 2015-16 to 2018-19 & 2021-22 of the assessee, revenue, and Cross Objections of the assessee are allowed for statistical purposes

ITA 2287/MUM/2023[2021-22]Status: DisposedITAT Mumbai11 Nov 2024AY 2021-22

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

Section 32(1)

103/Mum/2023 Jet Privilege Pvt. Ltd. that during the year under consideration the assessee has made the following additions to the intangible assets against which the depreciation is claimed. 3. The AO also noticed that Note No. 27 of the financial statements filed by the assessee contains the following statement with ... Consequently, the goodwill of Rs.13,013,742,680 arising from said acquisition is disclosed in the balance sheet, under the heading Intangible assets.” 4. The assessee submitted before the AO that the assessee has acquired Jet Privilege Frequent Flyer Program (JPFFP) from M/s Jet Airways India Ltd. under slum sale

Dy Commissioner of Income Tax CC-5(2), Mumbai vs. Jet Privilege Private Limited, Mumbai

In the result, the appeals for AY 2015-16 to 2018-19 & 2021-22 of the assessee, revenue, and Cross Objections of the assessee are allowed for statistical purposes

ITA 2163/MUM/2023[2017-18]Status: DisposedITAT Mumbai11 Nov 2024AY 2017-18

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

Section 32(1)

103/Mum/2023 Jet Privilege Pvt. Ltd. that during the year under consideration the assessee has made the following additions to the intangible assets against which the depreciation is claimed. 3. The AO also noticed that Note No. 27 of the financial statements filed by the assessee contains the following statement with ... Consequently, the goodwill of Rs.13,013,742,680 arising from said acquisition is disclosed in the balance sheet, under the heading Intangible assets.” 4. The assessee submitted before the AO that the assessee has acquired Jet Privilege Frequent Flyer Program (JPFFP) from M/s Jet Airways India Ltd. under slum sale

Dy Commissioner of Income Tax CC-5(2), Mumbai vs. Jet Privilege Private Limited, Mumbai

In the result, the appeals for AY 2015-16 to 2018-19 & 2021-22 of the assessee, revenue, and Cross Objections of the assessee are allowed for statistical purposes

ITA 2162/MUM/2023[2015-2016]Status: DisposedITAT Mumbai11 Nov 2024AY 2015-2016

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

Section 32(1)

103/Mum/2023 Jet Privilege Pvt. Ltd. that during the year under consideration the assessee has made the following additions to the intangible assets against which the depreciation is claimed. 3. The AO also noticed that Note No. 27 of the financial statements filed by the assessee contains the following statement with ... Consequently, the goodwill of Rs.13,013,742,680 arising from said acquisition is disclosed in the balance sheet, under the heading Intangible assets.” 4. The assessee submitted before the AO that the assessee has acquired Jet Privilege Frequent Flyer Program (JPFFP) from M/s Jet Airways India Ltd. under slum sale

Dy Commissioner of Income Tax CC-5(2), Mumbai vs. Jet Privilege Private Limited, Mumbai

In the result, the appeals for AY 2015-16 to 2018-19 & 2021-22 of the assessee, revenue, and Cross Objections of the assessee are allowed for statistical purposes

ITA 2161/MUM/2023[2018-2019]Status: DisposedITAT Mumbai11 Nov 2024AY 2018-2019

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

Section 32(1)

103/Mum/2023 Jet Privilege Pvt. Ltd. that during the year under consideration the assessee has made the following additions to the intangible assets against which the depreciation is claimed. 3. The AO also noticed that Note No. 27 of the financial statements filed by the assessee contains the following statement with ... Consequently, the goodwill of Rs.13,013,742,680 arising from said acquisition is disclosed in the balance sheet, under the heading Intangible assets.” 4. The assessee submitted before the AO that the assessee has acquired Jet Privilege Frequent Flyer Program (JPFFP) from M/s Jet Airways India Ltd. under slum sale

Dy Commissioner of Income Tax CC-5(2), Mumbai vs. Jet Privilege Private Limited, Mumbai

In the result, the appeals for AY 2015-16 to 2018-19 & 2021-22 of the assessee, revenue, and Cross Objections of the assessee are allowed for statistical purposes

ITA 2160/MUM/2023[2016-2017]Status: DisposedITAT Mumbai11 Nov 2024AY 2016-2017

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

Section 32(1)

103/Mum/2023 Jet Privilege Pvt. Ltd. that during the year under consideration the assessee has made the following additions to the intangible assets against which the depreciation is claimed. 3. The AO also noticed that Note No. 27 of the financial statements filed by the assessee contains the following statement with ... Consequently, the goodwill of Rs.13,013,742,680 arising from said acquisition is disclosed in the balance sheet, under the heading Intangible assets.” 4. The assessee submitted before the AO that the assessee has acquired Jet Privilege Frequent Flyer Program (JPFFP) from M/s Jet Airways India Ltd. under slum sale

Jet Privilege Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle-5(2) (Ershtwhile Deputy Commissioner of Income-Tax-10(2)(1), Mumbai

In the result, the appeals for AY 2015-16 to 2018-19 & 2021-22 of the assessee, revenue, and Cross Objections of the assessee are allowed for statistical purposes

ITA 1956/MUM/2023[2018-19]Status: DisposedITAT Mumbai11 Nov 2024AY 2018-19

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

Section 32(1)

103/Mum/2023 Jet Privilege Pvt. Ltd. that during the year under consideration the assessee has made the following additions to the intangible assets against which the depreciation is claimed. 3. The AO also noticed that Note No. 27 of the financial statements filed by the assessee contains the following statement with ... Consequently, the goodwill of Rs.13,013,742,680 arising from said acquisition is disclosed in the balance sheet, under the heading Intangible assets.” 4. The assessee submitted before the AO that the assessee has acquired Jet Privilege Frequent Flyer Program (JPFFP) from M/s Jet Airways India Ltd. under slum sale

Jet Privilege Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle-5(2) (Ershtwhile Deputy Commissioner of Income-Tax-10(2)(1), Mumbai

In the result, the appeals for AY 2015-16 to 2018-19 & 2021-22 of the assessee, revenue, and Cross Objections of the assessee are allowed for statistical purposes

ITA 1955/MUM/2023[2017-2018]Status: DisposedITAT Mumbai11 Nov 2024AY 2017-2018

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

Section 32(1)

103/Mum/2023 Jet Privilege Pvt. Ltd. that during the year under consideration the assessee has made the following additions to the intangible assets against which the depreciation is claimed. 3. The AO also noticed that Note No. 27 of the financial statements filed by the assessee contains the following statement with ... Consequently, the goodwill of Rs.13,013,742,680 arising from said acquisition is disclosed in the balance sheet, under the heading Intangible assets.” 4. The assessee submitted before the AO that the assessee has acquired Jet Privilege Frequent Flyer Program (JPFFP) from M/s Jet Airways India Ltd. under slum sale

Jet Privilege Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle-5(2) (Ershtwhile Deputy Commissioner of Income-Tax-10(2)(1), Mumbai

In the result, the appeals for AY 2015-16 to 2018-19 & 2021-22 of the assessee, revenue, and Cross Objections of the assessee are allowed for statistical purposes

ITA 1954/MUM/2023[2016-2017]Status: DisposedITAT Mumbai11 Nov 2024AY 2016-2017

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

Section 32(1)

103/Mum/2023 Jet Privilege Pvt. Ltd. that during the year under consideration the assessee has made the following additions to the intangible assets against which the depreciation is claimed. 3. The AO also noticed that Note No. 27 of the financial statements filed by the assessee contains the following statement with ... Consequently, the goodwill of Rs.13,013,742,680 arising from said acquisition is disclosed in the balance sheet, under the heading Intangible assets.” 4. The assessee submitted before the AO that the assessee has acquired Jet Privilege Frequent Flyer Program (JPFFP) from M/s Jet Airways India Ltd. under slum sale

Jet Privilege Private Limited, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle-5(2) (Ershtwhile Deputy Commissioner of Income-Tax-10(2)(1), Mumbai

In the result, the appeals for AY 2015-16 to 2018-19 & 2021-22 of the assessee, revenue, and Cross Objections of the assessee are allowed for statistical purposes

ITA 1953/MUM/2023[2015-2016]Status: DisposedITAT Mumbai11 Nov 2024AY 2015-2016

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

Section 32(1)

103/Mum/2023 Jet Privilege Pvt. Ltd. that during the year under consideration the assessee has made the following additions to the intangible assets against which the depreciation is claimed. 3. The AO also noticed that Note No. 27 of the financial statements filed by the assessee contains the following statement with ... Consequently, the goodwill of Rs.13,013,742,680 arising from said acquisition is disclosed in the balance sheet, under the heading Intangible assets.” 4. The assessee submitted before the AO that the assessee has acquired Jet Privilege Frequent Flyer Program (JPFFP) from M/s Jet Airways India Ltd. under slum sale

People Care Hospitals Private Limited, Faridabad vs. ITO, Ward 2(1), Faridabad

In the result, the appeals of the assesses are allowed

ITA 100/DEL/2021[2016-17]Status: DisposedITAT Delhi08 Nov 2024AY 2016-17

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2016-17 People Care Hospitals Private Vs Ito Limited, Plot No.1066, Baba Ward- 2 (1) Nagar, Near Janta Barat Ghar, Faridabad Old Faridabad, Haryana 121002 Pan No.Aagcp8745G (Appellant) (Respondent) Assessment Year: 2016-17 Geranium Barkers Pvt. Ltd. Vs Ito 103/B, Near Shyamji Mandir Ward-1 (3) Malerna Road, Adarsh Nagar, Faridabad Ballabgarh Haryana -122004 Pan No.Aafcg3396P (Appellant) (Respondent) Assessment Year: 2016-17 Riven Health Club Pvt. Ltd. Vs Ito Ff-9, Vishnu Place Near Ward- 2 (2) Neelam Flyover Sector-20B Faridabad Faridabad Haryana121001 Pan No. Aagcr1343A (Appellant) (Respondent) Appellants By Sh. Rajeev Saxena, Advocate Ms. Sumangla Saxena, Advocate Sh. Dishant Sethi, Advocate

Section 131oSection 142(1)Section 143Section 143(2)Section 143(3)Section 251(1)Section 271(1)(c)Section 56(2)(viib)Section 68

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, patents, copyrights, trademarks, licences, franchises or any other business or commercial rights of similar nature, whichever is higher;" Further ... also recognized and encouraging the start-ups." iii) DQ (International) Ltd. vs. ACIT (ITA 151/Hyd/2015) "10...... In our considered view, for valuation of an intangible asset, only the future projections along can be adopted and such valuation cannot be reviewed with actual after 3 or 4 years down the line

Riven Health Club Pvt. Ltd., Faridabad vs. ITO Ward-2(2), Faridabad

In the result, the appeals of the assesses are allowed

ITA 103/DEL/2021[2016-17]Status: DisposedITAT Delhi06 Nov 2024AY 2016-17

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2016-17 People Care Hospitals Private Vs Ito Limited, Plot No.1066, Baba Ward- 2 (1) Nagar, Near Janta Barat Ghar, Faridabad Old Faridabad, Haryana 121002 Pan No.Aagcp8745G (Appellant) (Respondent) Assessment Year: 2016-17 Geranium Barkers Pvt. Ltd. Vs Ito 103/B, Near Shyamji Mandir Ward-1 (3) Malerna Road, Adarsh Nagar, Faridabad Ballabgarh Haryana -122004 Pan No.Aafcg3396P (Appellant) (Respondent) Assessment Year: 2016-17 Riven Health Club Pvt. Ltd. Vs Ito Ff-9, Vishnu Place Near Ward- 2 (2) Neelam Flyover Sector-20B Faridabad Faridabad Haryana121001 Pan No. Aagcr1343A (Appellant) (Respondent) Appellants By Sh. Rajeev Saxena, Advocate Ms. Sumangla Saxena, Advocate Sh. Dishant Sethi, Advocate

Section 131oSection 142(1)Section 143Section 143(2)Section 143(3)Section 251(1)Section 271(1)(c)Section 56(2)(viib)Section 68

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, patents, copyrights, trademarks, licences, franchises or any other business or commercial rights of similar nature, whichever is higher;" Further ... also recognized and encouraging the start-ups." iii) DQ (International) Ltd. vs. ACIT (ITA 151/Hyd/2015) "10...... In our considered view, for valuation of an intangible asset, only the future projections along can be adopted and such valuation cannot be reviewed with actual after 3 or 4 years down the line