“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

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

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

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

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

M/S I & B Seeds Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore

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

ITA 3415/BANG/2018[2015-16]Status: DisposedITAT Bangalore15 Jun 2022AY 2015-16

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2015-16

For Appellant: Shri Nitish Ranjan, A.RFor Respondent: Shri Sankar Ganesh K, D.R

Section 43(1)

facts of the issue are that during assessment proceedings it was observed by the AO that the assessee had claimed depreciation @ 25% on intangible assets of Rs. 17,39,83,689/-. The assessee was asked by the AO to provide the details of intangible assets. In response to the same ... assessee company in a slump sale agreement. As regards balance amount of Rs.19,60,780/- the same was stated. to be value of intangible assets as recorded in the books of M/s. Indus Seeds, which was taken over by the assessee company in slump sale agreement. The assessee submitted that

M/S Applied Materials India Private Limited, Bangalore vs. Income Tax Officer Ward-1(1)(1), Bangalore

In the result, the appeal of the assessee is partly allowed

ITA 3403/BANG/2018[2014-15]Status: DisposedITAT Bangalore08 Jun 2022AY 2014-15

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bangalore

Section 143(3)Section 92(1)Section 92ASection 92B(1)Section 92C

developed in-house. During the relevant financial year, the company has added Rs.708 million IT(TP)A No.3403/Bang/2018 Page 16 of 44 worth of intangible assets. Also, the company is engaged in diversified activities including cloud computing, infrastructure management, analytics & information management etc. Further, L&T enjoys significant brand value

Radiant Life Care Mumbai P. Ltd., Mumbai vs. Pr. CIT-3, Mumbai

In the result, the appeals of the assessee are dismissed

ITA 896/MUM/2021[2016-17]Status: DisposedITAT Mumbai31 May 2022AY 2016-17

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2015-16 & Assessment Year: 2016-17 Radiant Life Care Mumbai Pvt. Ltd., Principle Commissioner Of 401, 4Th Floor Man Excellenza, S.V. Income Tax Mumbai-3, Road, Vile Parle (W), Vs. R. No. 612, 6Th Floor, Aayakar Mumbai-400056. Bhavan, Maharishi Karve Road, Mumbai-400020. Pan No. Aagcr 9198 D Appellant Respondent

For Appellant: Dr. K. Shivaram, Sr. Advocate &For Respondent: Mr. Prabhat Kumar Gupta, CIT-DR

Section 143(3)Section 263Section 32Section 56(2)

depreciation after making proper & specific enquiry with reference to Section 56(2) (viib) for valuation of shares and Section 32 for depreciation on intangible asset. The assessment order was passed by the Assessing Officer after due application of mind and after making due investigation / enquiries, which fact is clearly borne ... Rs.25 crores as non-refundable deposit. According to the assessee, the said amount was non-refundable, therefore, the assessee capitalized the said amount as intangible asset eligible for depreciation u/s 32 of the Income Tax Act, 1961 (in short ‘the Act’) and claimed depreciation on the same. 3.1 During

Radiant Life Care Mumbai P. Ltd., Mumbai vs. Pr. CIT-3, Mumbai

In the result, the appeals of the assessee are dismissed

ITA 895/MUM/2021[2015-16]Status: DisposedITAT Mumbai31 May 2022AY 2015-16

For Appellant: Dr. K. Shivaram, Sr. Advocate &For Respondent: Mr. Prabhat Kumar Gupta, CIT-DR

Section 143(3)Section 263Section 32Section 56(2)

M/S. L G Soft India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 4(1)(1), Bengaluru

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

ITA 2412/BANG/2019[2015-16]Status: DisposedITAT Bangalore31 May 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Sri K.R. Vasudevan, A.RFor Respondent: Sri Pradeep Kumar, DR

Section 234ASection 92CSection 92E

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 page115 as under:- Intangible Assets of Group 2012-13 (in Rs.Millions) Acquired Software contractual Total rights Gross block (At cost ... Further, the capital expenditure towards R&D was only Rs.0.28 million, which clearly show that the R&D activities are routine. The value of intangible assets was only Rs.162.85 million constituting 1.31% of operating revenue. There is no reference to any intangible assets or patent owned or developed

M/S. Te Connectivity Services India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

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

ITA 300/BANG/2021[2016-17]Status: DisposedITAT Bangalore26 May 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No.300/Bang/2021 Assessment Year : 2016-17

For Appellant: Shri Sriram Sheshadri & Ms. Amulya K., CAsFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(3)

benefits. These benefits are not immediate but generally accrued over a period of time. 6. It is submitted that the said goodwill as an intangible asset, was not recorded or recognised by the Transferor, i.e., TECGSS, prior to the said acquisition but arose pursuant to the acquisition on account ... goodwill is the process of expensing the cost of a goodwill over the projected life of the asset for tax or accounting purposes. The intangible assets, such as goodwill, patents and trademarks are amortized into an expense account whereas tangible assets are instead written off through depreciation

M/S. Wipro Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-7(1)(2), Bangalore

In the result, the appeal filed by the assessee is treated as partly allowed for statistical purposes

ITA 2556/BANG/2019[2015-16]Status: HeardITAT Bangalore23 May 2022AY 2015-16

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranit(Tp)A No.2556/Bang/2019 Assessment Year : 2015-16

For Appellant: Shri S. Ganesh, Sr. ARFor Respondent: Shri T. Roumuan Paite, D.R

Section 143(3)

However as per the remand report the AO raised alternative argument that the depreciation may be restricted to 25%, as the assessee was creating intangible assets. The information with regard to the nature of assets created and put to use is not made available to the Panel. Hence ... Talisma Corporation P Ltd (ITA 515/2007). The Ld DRP called for a remand report from AO, who opined that the assessee has only created “intangible assets” in the nature of “Software platform” and “software codes” and it cannot qualify as Scientific research activity. He also expressed the view that

Tree Hill Estates Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-7(1)(1), Bangalore

In the result, the appeal of the assessee is dismissed

ITA 1395/BANG/2018[2013-14]Status: DisposedITAT Bangalore18 May 2022AY 2013-14

Bench: Smt. Beena Pillai & Ms. Padmavathy Sassessment Year : 2013-14

For Appellant: Shri Padamchand Khincha, CAFor Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

will look at the relevant clauses of AS-26 as follows:- “2. If another Accounting Standard deals with a specific type of intangible asset, an enterprise applies that Accounting Standard instead of this Standard. For example, this Statement does not apply to: (a) intangible assets held by an enterprise ... asset. 36. In some cases, expenditure is incurred to generate future economic benefits, but it does not result in the creation of an intangible asset that meets the recognition criteria in this Standard. Such expenditure is often described as contributing to internally generated goodwill. Internally generated goodwill is not recognised

M/S. Ocwen Financial Solutions Private Limited, Bengaluru vs. Joint Commissioner of Income Tax, Special Range - 5, Bangalore

In the result appeal filed by the assessee stands partly allowed

ITA 2411/BANG/2019[2015-16]Status: DisposedITAT Bangalore13 May 2022AY 2015-16

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 2411/Bang/2019 Assessment Year : 2015-16 M/S. Ocwen Financial Solutions Pvt. Ltd., Pritech Park, Block 12, The Joint Commissioner Unit 2, 5B & 6A Floors, Of Income-Tax, Bellandur Village, Special Range-5, Sarjapur Marathahalli Bangalore. Ring Road, Vs. Bangalore – 560 103. Pan: Aaaco3764E Appellant Respondent : Shri K.R. Vasudevan & Assessee By Ms. Rashmi, Advocates : Dr. Manjunath Karkihalli, Revenue By Cit-Dr Date Of Hearing : 02-03-2022 Date Of Pronouncement : 13-05-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 24/09/2019 Passed By The Ld.Jcit, Special Range-5, Bangalore Under Section 143 (3) R.W.S 144C (13) Of The Act, For Assessment Year 2015-16 On Following Grounds Of Appeal: “I. Transfer Pricing The Grounds Mentioned Hereinafter Are Without Prejudice To One Another.

For Respondent: Shri K.R. Vasudevan &

Section 133(6)Section 143Section 92C

employed Tangible assets Ocwen India uses the following tangible assets for carrying out its business: Leasehold improvement;  Computer hardware; and  Office and other equipment  Intangible Assets Ocwen India does not own any non-routine intangibles. Page 10 of 24 IT(TP)A No. 2411/Bang/2019 Risk Analysis Risks are those business ... seen from pages 5, 14 and 33 of its Annual Report. (iii) It is engaged in research and development. II Ownership of intangible assets This company, Infosys, owns intangible assets worth Rs.19 Crores during the year as can be seen from pages 16, 47 and 58 of its Annual Report

Real Gold Developers LLP, Mumbai vs. ACIT, RG. 20(3), Mumbai

In the result, the appeals filed by the assessee are allowed and appeal filed by the revenue is dismissed

ITA 1899/MUM/2021[2014-15]Status: DisposedITAT Mumbai29 Apr 2022AY 2014-15

Bench: Shri Pavan Kumar Gadale & Shri S Rifaur Rahmanita Nos. 1899 & 1900/Mum/2021 (A.Ys: 2014-15 & 2017-18)

For Appellant: Mr.Malav .P. Sheth.ARFor Respondent: Mr.T.Shankar .DR

Section 143(1)Section 143(2)Section 143(3)Section 32

furniture, being tangible assets; (ii) Know-how, patents, copyrights, trade marks, licences, franchises or any other business or commercial rights of similar nature, being intangible assets acquired on or after the 1" day of April, 1998 Owned, wholly or party, by the assessee and used for the purposes

Novell Software Development (India) Private Limited, Bangalore vs. ITO, Bangalore

In the result, appeal filed by assessee stands allowed and appeal filed by the revenue stands dismissed

ITA 319/BANG/2016[2011-12]Status: DisposedITAT Bangalore29 Apr 2022AY 2011-12

Bench: Shri. Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 280/Bang/2016 Assessment Year : 2011-12 M/S. Micro Focus Software India Pvt. Ltd. (Earlier Known As Novell Software Development The Income Tax (India) Pvt. Ltd.), Officer, Bagmane Tech Park ‘D’ Ward – 4 (1)(3), Block, Bangalore. ‘Laurel’ 65/2, Vs. C V Raman Nagar, Byrasandra, Bangalore – 560 093. Pan: Aaacn6992K Appellant Respondent & It(Tp)A No. 319/Bang/2016 Assessment Year : 2011-12 (By Assessee) : Smt. Tanmayee Rajkumar, Assessee By Advocate : Dr. Manjunath Karkihalli, Cit Revenue By (Dr) Date Of Hearing : 03-03-2022 Date Of Pronouncement : 29-04-2022 Order Per Beena Pillaipresent Cross Appeals Has Been Filed By Revenue As Well As Assessee Against Order Dated 29.12.2015 Passed By Ld.Ito Ward 5(1)(1)

Section 143(3)Section 144C(13)Section 92C(3)

support, project documentation and web publishing. Assets employed: It has been submitted in TP study that, assessee do not own any non-routine valuable intangible assets. Risks Assumed: It has been submitted that assessee does not assume any significant risks as entire contract is entered into by AE with

ITO Ward - 5(1)(1), Bangalore vs. M/S Novell Software Development (India) Pvt. Ltd., Bangalore

In the result, appeal filed by assessee stands allowed and appeal filed by the revenue stands dismissed

ITA 280/BANG/2016[2011-12]Status: DisposedITAT Bangalore29 Apr 2022AY 2011-12

Section 143(3)Section 144C(13)Section 92C(3)

Sagar Damoh Toll Roads Limited, Mumbai vs. Asst CIT 8(1)(2), Mumbai

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

ITA 3147/MUM/2019[2013-14]Status: DisposedITAT Mumbai28 Apr 2022AY 2013-14

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadalesagar Damoh Toll Vs. Acit, Circle – 8(1)(2) Roads Ltd Room No. 651, 6Th 513A, 5Th Floor, Floor, Aayakar Kohinoor City, Kirol Bhavan, Mk Road, Road, Off Lbs Marg, Mumbai – 400020. Kurla, Mumbai – 400070 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aacce2160Q Appellant .. Respondent Appellant By : Shri. K. Shivaram.Ar Respondent By : Shri Ajay K. Shrivastava.Dr Date Of Hearing 22.03.2022 Date Of Pronouncement 29.03.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals)-14, Mumbai Passed 143(3) & 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri. K. Shivaram.ARFor Respondent: Shri Ajay K. Shrivastava.DR

Section 143(1)Section 143(2)Section 250Section 32(1)(ii)

learned CIT(A) has erred in law and in facts and in circumstances of the case by disallowing depreciation on Intangible Assets (i.e. Concessionaire I Toll Collection Rights) and allowing amortization of construction cost of toll road over a period of toll collection rights i.e. 12 years, resulting ... disallowance of Rs.18,84,19,089 (depreciation claimed on intangible assets Rs.31 52,76,735!- and amortization allowed Rs.12,68,57,6461-). 2.2. The learned CIT(A) has erred in law and in facts and in circumstances of the case in not accepting the contention of the Appellant that Concessionaire

M/S. Steer Engineering Pvt. Ltd., Bengaluru vs. Deputy Commissioner of Income-Tax, Circle-6(1)(2), Bengaluru

In the result, appeal of the Assessee is partly allowed

ITA 2071/BANG/2018[2012-13]Status: DisposedITAT Bangalore27 Apr 2022AY 2012-13

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathyassessment Year : 2012-13 M/S. Steer Engineering Private Limited, Vs. Dcit, No.290, 4Th Main, 4Th Phase, Circle – 6(1)(2), Peenya Industrial Area, Nagawara, Bengaluru. Bengaluru – 560 058. Pan : Aabcs 8840 E Appellant Respondent Assessee By : Shri. Narendra Jain, Advocate Revenue By : Mrs. Susan D. George, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 18.04.2022 Date Of Pronouncement : 27.04.2022

For Appellant: Shri. Narendra Jain, AdvocateFor Respondent: Mrs. Susan D. George, CIT(DR)(ITAT), Bengaluru

Section 144CSection 92(1)Section 92ASection 92A(1)Section 92CSection 92C(2)Section 92F

elements of extruders 5 Steer China Corporation Purchase of Fixed Assets 9,137,883 6 Steer China Corporation Purchase of Intangible Assets 32,991,505 7 Steer Japan Corporation Commission on sales 13,891,128 8 Steer America Inc Commission on sales 140,536,066 9 Chindia Company Ltd, Interest

Ashish Life Science P. Ltd., Mumbai vs. Asst. CIT-Circle-9(1)(2), Mumbai

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

ITA 964/MUM/2021[2017-18]Status: DisposedITAT Mumbai26 Apr 2022AY 2017-18

Bench: Shri Amarjit Singh, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No. 964/Mum/2021 (निर्धारण वर्ा / Assessment Year: 2017-18) Ashish Life Science Pvt. Ltd. बिधम/ Acit-Cir, 9(1)(2) 210, 2Nd Floor, Aayakar 213, Laxmi Plaza Industrial Vs. Estate, New Link Road, Bhavan, M. K. Road, Andheri, Mumbai-400053. Mumbai-400020. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabcb4093N (अपीलाथी /Appellant) .. (प्रत्यथी / Respondent) Assessee By: Shri Dhaval Shah Revenue By: Shri K.P.R.R. Murty सुनवाई की तारीख / Date Of Hearing: 22/03/2022 घोषणा की तारीख /Date Of Pronouncement: 26/04/2022 आदेश / O R D E R Per Amarjit Singh, Jm: The Assessee Has Filed The Present Appeal Against The Order Dated 15.04.2021 Passed By The National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As The “(Nfac)”] In The Relevant A.Y.2017-18. 2. The Assessee Has Raised The Following Grounds: - “1. The Ld. Cit(A) Has Erred In Law & In Facts In Passing The Order U/S. 250 Of The Act Through National Faceless Appeal Center Which Is Bad In Law & Invalid. 2. The Ld. Cit(A) Has Erred In Law & In Facts Confirming The Assessment Order Passed U/S. 143(3) Of The Act Without. Considering The Written Submissions Filed By The Appellant. As Such, The Order Is

For Appellant: Shri Dhaval ShahFor Respondent: Shri K.P.R.R. Murty

Section 143(1)Section 143(2)Section 143(3)Section 250

revenue expenses, when the expense were incurred for registration of Trademark in that country and also for registration of Patent, which are intangible assets under section 32(1)(ii) of the Act? ITA. No.964/Mum/2021 A.Y. 2017-18 These questions pertain to the expenditure incurred by the assessee towards product registration ... expenditure only enable the assessee to run the existing business smoothly and therefore, it cannot be stated that the assessee acquired any tangible or intangible assets. With respect to patent and trademark registration, the Tribunal held that for protection of result of the research of the assessee, such patent

M/S. Arkema Chemicals India P. Ltd., Navi Mumbai vs. The ACIT-15(1)(1), Mumbai

ITA 1032/MUM/2021[2017-18]Status: DisposedITAT Mumbai22 Apr 2022AY 2017-18

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm M/S Arkema Chemicals India The Asst. Commissioner Of P. Ltd. Income Tax, Circle 15(1)(1), Room No.470, 4Th Floor, D043, (1), Trans Thane Creek, Midc Industrial Areal Aayakar Bhavan, M.K. Road, Vs. Shirvane Village, Navi Mumbai-400 020 Mumbai-400 706 (Appellant) (Respondent) Pan No. Aaacc6482F

For Appellant: Shri Ajay R Singh, ARFor Respondent: Shri Vinod Bhaskaran, Sr. Dr

Section 115JSection 143(3)Section 32

claimed by the assessee considering the same as computer or @ 25% as claimed by the learned assessing officer considering the software as intangible asset. The disallowance of depreciation on software ERP SAP is of Rs. 3,84,70,669/-. 04. The fact shows that the during the year assessee ... learned Assessing Officer assessee has acquired only the license and hence, it is eligible for depreciation at the rate of 25% applicable to intangible assets. The Assessing Officer relied on the decision of the co-ordinate bench in case of M/s Harland Clarke Holding Software India Pvt. Ltd. Vs. DCIT

Ansr Global Corporation Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-1(1)(1), Bangalore

In the result, the appeal is partly allowed

ITA 225/BANG/2021[2016-17]Status: DisposedITAT Bangalore19 Apr 2022AY 2016-17

Bench: Shri N. V. Vasudevan & Ms. S. Padmavathyit(Tp)A No.225/Bang/2021 Assessment Year : 2016-17 M/S. Ansr Global Corporation Pvt. Ltd., Acit, Vs. Ground Floor, Block L1, Circle – 1(1)(1), Manyata Embassy Business Park, Bengaluru. Sez, Outer Ring Road, Nagwara, Bengaluru-560 045. Pan : Aaecn 7296 E Appellant Respondent

For Appellant: Shri. K. R. Vasudevan, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144C(13)Section 92Section 92(1)Section 92B(1)

company is based on inconsistencies in the financial statement of this company. The argument advanced in this regard were that the value of the intangible assets to the total assets is very high and that indicates that the functions of this company could be dissimilar. Regarding the argument that there ... statements of this company, these features do not affect the comparability. By merely pointing out that there is a substantial increase in value of intangible assets, the Assessee cannot seek to exclude this company from the list of comparable companies, unless the Assessee is able to show that the presence

M/S. Sogefi Mnr Filtration India Pvt Lld, Bangaluru vs. Deputy Commissioner of Income Tax, Circle-12(2), Bangaluru

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 2076/BANG/2018[2011-12]Status: DisposedITAT Bangalore19 Apr 2022AY 2011-12

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

For Appellant: NoneFor Respondent: Shri. Priyadarshi Mishra, Addl. CIT(DR)(ITAT), Bengaluru

Section 143(3)

succeeded a partnership firm (firm) w.e.f. 1 February 2005. Before the firm was converted into private limited company, the firm had revalued all its intangible assets using standard valuation methods. All assets and liabilities (including the intangible assets) of the firm were transferred to the taxpayer and in consideration ... Nos.2074 to 2076/Bang/2018 Page 7 of 9 shares (at a premium) to the partners of the firm. The taxpayer claimed depreciation on the intangible assets. The Assessing Officer disallowed the Assessee’s claim of depreciation on the basis that the Intangible assets valued in the hands of the Assessee

M/S. Sogefi Mnr Filtration India Pvt Ltd, Bangaluru vs. Deputy Commissioner of Income Tax, Circle-12(2), Bengaluru

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 2075/BANG/2018[2010-11]Status: DisposedITAT Bangalore19 Apr 2022AY 2010-11

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

For Appellant: NoneFor Respondent: Shri. Priyadarshi Mishra, Addl. CIT(DR)(ITAT), Bengaluru

Section 143(3)

M/S. Sogefi Mnr Filtration India Pvt Ltd, Bangalore vs. Deputy Commissioner of Income Tax, Circle-12(2), Bengaluru

In the result, all the appeals of the assessee are allowed for statistical purposes

ITA 2074/BANG/2018[2009-10]Status: DisposedITAT Bangalore19 Apr 2022AY 2009-10

Bench: Shri N. V. Vasudevan & Ms. Padmavathy S

For Appellant: NoneFor Respondent: Shri. Priyadarshi Mishra, Addl. CIT(DR)(ITAT), Bengaluru

Section 143(3)