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In the result, both the appeals of the assessee are partly allowed for statistical purposes
Bench: Shri Waseem Ahmed & Shri Soundararajan K
13 of 53 Ltd on such intangibles, no depreciation could be allowed to the assessee. 22.4 The AO further observed that the valuation exercise was primarily undertaken to comply with accounting requirements under AS-26 and Indian GAAP, which by itself does not confer eligibility to claim depreciation under the Income-tax Act. The AO also referred to judicial precedents