EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE
In the result, both the appeals of the assessee are partly allowed for statistical purposes
ITA 293/BANG/2025[2020-21]Status: DisposedITAT Bangalore30 Jan 2026AY 2020-21
Bench: Shri Waseem Ahmed & Shri Soundararajan K
For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90
reassessment proceedings were initiated. Thus, the Revenue has accepted the allowability of depreciation on identical assets created based on identical business transfer agreement in earlier years.
In the absence of any change in facts or law, the Revenue cannot take a contradictory stand in the year under consideration. The settled principle that the Revenue cannot blow hot and cold