ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43(6)(c) and section 55(2)(a)(ii) to hold that no depreciation could be allowed on goodwill arising in a tax-neutral amalgamation on the footing that there was no cost or that the cost in the hands of the amalgamating company was nil. 4. In appeal, the assessee inter alia pointed out before the learned

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD, AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43(6)(c) and section 55(2)(a)(ii) to hold that no depreciation could be allowed on goodwill arising in a tax-neutral amalgamation on the footing that there was no cost or that the cost in the hands of the amalgamating company was nil. 4. In appeal, the assessee inter alia pointed out before the learned

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43(6)(c) and section 55(2)(a)(ii) to hold that no depreciation could be allowed on goodwill arising in a tax-neutral amalgamation on the footing that there was no cost or that the cost in the hands of the amalgamating company was nil. 4. In appeal, the assessee inter alia pointed out before the learned

ACIT CC-1(3), AHMEDABAD, AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43(6)(c) and section 55(2)(a)(ii) to hold that no depreciation could be allowed on goodwill arising in a tax-neutral amalgamation on the footing that there was no cost or that the cost in the hands of the amalgamating company was nil. 4. In appeal, the assessee inter alia pointed out before the learned

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43(6)(c) and section 55(2)(a)(ii) to hold that no depreciation could be allowed on goodwill arising in a tax-neutral amalgamation on the footing that there was no cost or that the cost in the hands of the amalgamating company was nil. 4. In appeal, the assessee inter alia pointed out before the learned

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING PRIVATE LIMITED, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

43(6)(c) and section 55(2)(a)(ii) to hold that no depreciation could be allowed on goodwill arising in a tax-neutral amalgamation on the footing that there was no cost or that the cost in the hands of the amalgamating company was nil. 4. In appeal, the assessee inter alia pointed out before the learned

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD2(1)(1), AHMEDABAD, AHMEDABAD

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

43,244/-. These amounts need to be verified and corrected. 4.5 Aggrieved by the ex-parte reassessments, the assessee preferred appeals before the CIT(A) raising both jurisdictional and substantive grounds. It was submitted that the assessments were vitiated due to non- service of statutory notices, as the Department had sent all communications to an incorrect email

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

43,244/-. These amounts need to be verified and corrected. 4.5 Aggrieved by the ex-parte reassessments, the assessee preferred appeals before the CIT(A) raising both jurisdictional and substantive grounds. It was submitted that the assessments were vitiated due to non- service of statutory notices, as the Department had sent all communications to an incorrect email

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

43,244/-. These amounts need to be verified and corrected. 4.5 Aggrieved by the ex-parte reassessments, the assessee preferred appeals before the CIT(A) raising both jurisdictional and substantive grounds. It was submitted that the assessments were vitiated due to non- service of statutory notices, as the Department had sent all communications to an incorrect email

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

43,244/-. These amounts need to be verified and corrected. 4.5 Aggrieved by the ex-parte reassessments, the assessee preferred appeals before the CIT(A) raising both jurisdictional and substantive grounds. It was submitted that the assessments were vitiated due to non- service of statutory notices, as the Department had sent all communications to an incorrect email

YAKIN JAYANTILAL SHAH,AHMEDABAD vs. ITO, WARD 2(1)(1), AHMEDABAD, AHMEDABAD

Bench: Ms. Suchitra R. Kamble & Makarand V.Mahadeokar

43,244/-. These amounts need to be verified and corrected. 4.5 Aggrieved by the ex-parte reassessments, the assessee preferred appeals before the CIT(A) raising both jurisdictional and substantive grounds. It was submitted that the assessments were vitiated due to non- service of statutory notices, as the Department had sent all communications to an incorrect email

BODAL CHEMICALS LTD.,,AHMEDABAD vs. THE ADDL.CIT.,RANGE-1,, AHMEDABAD

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

5. Aggrieved assessee preferred an appeal to the learned CIT (A). The assessee before the learned CIT (A) submitted that it is the 2nd year 6. for claiming the depreciation on the goodwill. As such the depreciation under section 32 of the Act was allowed in the assessment framed for the immediately preceding assessment year 2006-07. The assessee

M/S. BODAL CHEMICAL LTD.,AHMEDABAD vs. THE ADD.CIT.,RANGE-1,, AHMEDABAD

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

5. Aggrieved assessee preferred an appeal to the learned CIT (A). The assessee before the learned CIT (A) submitted that it is the 2nd year 6. for claiming the depreciation on the goodwill. As such the depreciation under section 32 of the Act was allowed in the assessment framed for the immediately preceding assessment year 2006-07. The assessee

BODAL CHEMICALS LTD.,AHMEDABAD vs. THE DCIT, CIRCLE-1, AHMEDABAD

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

5. Aggrieved assessee preferred an appeal to the learned CIT (A). The assessee before the learned CIT (A) submitted that it is the 2nd year 6. for claiming the depreciation on the goodwill. As such the depreciation under section 32 of the Act was allowed in the assessment framed for the immediately preceding assessment year 2006-07. The assessee

THE ACIT, CENTRAL CIRCLE-1(1),, AHMEDABAD vs. M/S. BODAL CHEMICAL LTD., AHMEDABAD

Bench: Shri Waseem Ahmed & Ms. Madhumita Roy

5. Aggrieved assessee preferred an appeal to the learned CIT (A). The assessee before the learned CIT (A) submitted that it is the 2nd year 6. for claiming the depreciation on the goodwill. As such the depreciation under section 32 of the Act was allowed in the assessment framed for the immediately preceding assessment year 2006-07. The assessee

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

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

section 14A was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee's own funds

SUZLON ENERGY LTD.,,AHMEDABAD vs. THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD

In the result the Ground Nos

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

section 14A was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee's own funds

THE DY. COMMISSIONER OF INCOME TAX CIRCLE-4(1)(1), AHMEDABAD vs. SUZLON ENERGY LTD.,, AHMEDABAD

In the result the Ground Nos

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

section 14A was squarely covered by Supreme Court in South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/ [2021] 10 SCC 153 wherein it was held that since interest free own funds available with assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of assessee's own funds