KOVALAM RESORT PRIVATE LIMITED ,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX 2(1)(1), MUMBAI

In the result, the appeal of the assessee for Assessment Year

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokar1. Ita No. 6580/Mum/2025 (Assessment Year: 2012-13) 2. Ita No. 6578/Mum/2025 (Assessment Year: 2013-14) & 3. Ita No. 6579/Mum/2025 (Assessment Year: 2014-15) Kovalam Resort Private Dcit 2(1)(1), Limited 561, Aayakar The Leela, Sahar, Andheri Vs. Bhavan, M. K. East, Mumbai-400 059 Road, Mumbai- 400 020 Pan/Gir No. Aaeck4804H (Applicant) (Respondent) Assessee By Shri Dharan Gandi & Shri Ravi Gupta, Ld. Ars Revenue By Shri Ritesh Misra, Ld. Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 30.01.2026

391 to 394 of the Companies Act, 1956, vide order dated 24.02.2012, with the appointed date as 01.09.2011, for a lump sum consideration of Rs. 500 crores. The assessee also took over liabilities amounting to Rs. 2 crores. 4. For Assessment Year 2012-13, the assessee filed its return of income on 25.09.2012 declaring total income

KOVALAM RESORT PRIVATE LIMTIED ,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX 2(1)(1), MUMBAI

In the result, the appeal of the assessee for Assessment Year

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokar1. Ita No. 6580/Mum/2025 (Assessment Year: 2012-13) 2. Ita No. 6578/Mum/2025 (Assessment Year: 2013-14) & 3. Ita No. 6579/Mum/2025 (Assessment Year: 2014-15) Kovalam Resort Private Dcit 2(1)(1), Limited 561, Aayakar The Leela, Sahar, Andheri Vs. Bhavan, M. K. East, Mumbai-400 059 Road, Mumbai- 400 020 Pan/Gir No. Aaeck4804H (Applicant) (Respondent) Assessee By Shri Dharan Gandi & Shri Ravi Gupta, Ld. Ars Revenue By Shri Ritesh Misra, Ld. Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 30.01.2026

391 to 394 of the Companies Act, 1956, vide order dated 24.02.2012, with the appointed date as 01.09.2011, for a lump sum consideration of Rs. 500 crores. The assessee also took over liabilities amounting to Rs. 2 crores. 4. For Assessment Year 2012-13, the assessee filed its return of income on 25.09.2012 declaring total income

TECHNO SHARES & STOCKS LTD,MUMBAI vs. ADDL CIT RG 4(2), MUMBAI

In the result, the appeal of assessee is allowed

Bench: Shri G.S. Pannu() : A.Y : 2008-09

depreciation on the cost of membership card. Is the cost of acquisition to be computed as per Section 50 of the Act or Section 55(2)(ab) of the Act. Further, what should be the period of holding of shares of BSE Ltd.; 13. At the outset, I make it clear that so far as the relevant factual matrix

ADITYA BIRLA FINANCE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME-TAX - 2(1)(1), MUMBAI

In the result, the appeal is partly allowed

depreciation on\nGoodwill which has been disallowed by the AO. Facts in brief are the\nWealth Management and Distribution (“WMD”) division of Aditya Birla\nMoney Mart Ltd. (“ABMML") demerged into the assessee through a\nCourt-approved Scheme of Arrangement under Sections 391

DCIT CEN CIR 1(4), MUMBAI vs. GRASIM INDUSTRIES LTD, MUMBAI

In the result, appeal of the revenue and the assessee are partly allowed, and the additional ground of the assessee is dismissed

Bench: Shri Narendra Kumar Billaiya & Shri Anikesh Banerjee

depreciation under section 32 of the Act. 53. The Ld. AR has submitted that the issue under consideration has consistently been decided in its favour by the coordinate benches of the ITAT, Mumbai. In particular, reliance has been placed on the decision of the Tribunal in the assessee’s own case for the immediately preceding AY 2009-10, in I.T.A

KEVA FRGRANCES PVT LTD.,MUMBAI vs. DY CIT 4 (2)(2), MUMBAI

In the result the appeal of the assessee is allowed and that of the Revenue is dismissed

Bench: Shri Rajesh Kumar & Shri Amarjit Singhassessment Year: 2016-17

depreciation on goodwill. 9. Further we also find merit in the contentions of the ld AR that the scheme of amalgamation is approved by the High Court after giving notice to the stakeholders including the Revenue to state its objections, if any, to the proposed amalgamation scheme. However revenue has raised no objection to the scheme of amalgamation. Therefore

MAHADHAN AGRITECH LIMITED (FORMERLY KNOWN AS SMARTCHEM TECHNOLOGIES LTD ,MUMBAI vs. COMMISSIONER OF INCOME TAX(APPEAL)--50, MUMAI

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

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

391–394 of the Companies Act, 1956 (now under Sections 230–232 of the Companies Act, 2013). The manner and methodology of the transaction including its valuation were determined in accordance with accepted accounting and valuation principles. 47. In a demerger, all assets are typically valued, often bringing to light self-generated assets that were previously unrecorded but already embedded

DCIT CENTRAL CIRCLE 8(1), MUMBAI vs. MAHADHAN AGRITECH LIMITED, PUNE

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

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

391–394 of the Companies Act, 1956 (now under Sections 230–232 of the Companies Act, 2013). The manner and methodology of the transaction including its valuation were determined in accordance with accepted accounting and valuation principles. 47. In a demerger, all assets are typically valued, often bringing to light self-generated assets that were previously unrecorded but already embedded

MAHADHAN AGRITECH LIMITED (FORMERLY KNOWN AS SMARTCHEM TECHNOLOGIES LIMITED ),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX , CENTRAL CIRCLE -8(1), MUMBAI

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

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

391–394 of the Companies Act, 1956 (now under Sections 230–232 of the Companies Act, 2013). The manner and methodology of the transaction including its valuation were determined in accordance with accepted accounting and valuation principles. 47. In a demerger, all assets are typically valued, often bringing to light self-generated assets that were previously unrecorded but already embedded

MAHADHAN AGRITECH LIMITED (FORMERLY KNOWN AS SMARTECH TECHNOLOGIES LTD ,MUMBAI vs. COMMISSIONER OF INCOME TAX (APPEALS)-MUMBAI.50, MUMBAI

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

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

391–394 of the Companies Act, 1956 (now under Sections 230–232 of the Companies Act, 2013). The manner and methodology of the transaction including its valuation were determined in accordance with accepted accounting and valuation principles. 47. In a demerger, all assets are typically valued, often bringing to light self-generated assets that were previously unrecorded but already embedded

DOW CHEMICALS INTERNATIONAL PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX-14(1)(2), MUMBAI

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

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

depreciation on customer relations and distribution network. Being aggrieved, the assessee is in appeal before us. 7. We have considered the submissions of both sides and perused the material available on record. In the present case, Rohm and Hass Company, USA along with all its subsidiaries were acquired by the Dow Chemical Company, USA. As part of the global legal

ABBOTT INDIA LTD,MUMBAI vs. ASST CIT CIR 2(1), MUMBAI

In the result, assessee’s appeal in ITA No 3472/Mum/2013 and ITA No

Bench: Shri Mahavir Singh & Shri Ramit Kochar

Section 143(2) of the Act, the AO has discussed this issue in detail in the assessment order darted 26th November, 2009 passed u/s 143(3) of the Act whereby the complete details were submitted before the A.O. and the A.O. allowed the deduction based upon the ratio of turnover to trading activity. The relevant portion of the assessment order

ABOTT INDIA LTD,MUMBAI vs. ASST CIT CIR 2(1), MUMBAI

In the result, assessee’s appeal in ITA No 3472/Mum/2013 and ITA No

Bench: Shri Mahavir Singh & Shri Ramit Kochar

Section 143(2) of the Act, the AO has discussed this issue in detail in the assessment order darted 26th November, 2009 passed u/s 143(3) of the Act whereby the complete details were submitted before the A.O. and the A.O. allowed the deduction based upon the ratio of turnover to trading activity. The relevant portion of the assessment order

ASSISTANT COMMISSIONER OF INCOME TAX-16(1), MUMBAI vs. VIACOM18 MEDIA PRIVATE LIMITED, MUMBAI

391 and 394 of Companies Act 1956, which was\napproved vide their Order dt. 15/12/2010 w.e.f. 01/04/2010 by the\nHon'ble High Court of Andhra Pradesh, merged into three companies\nnamely:\n(1) M/s. Eenadu Television Private Ltd. {in short “ETPL\"} ;\n(2) M/s. Prism TV Private Ltd. {in short “PTVPL”} and,\n(3) M/s. Panorama Television Private

DOW CHEMICALS INTERNATIONAL PRIVATE LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TA-14(1)(2), MUMBAI

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

depreciation on goodwill. Being aggrieved, the assessee is in appeal before us. 9. We have considered the submissions of both sides and perused the material available on record. Before dealing with submissions of both parties on this issue, it is relevant to note certain basic facts of the present case. Rohm and Hass Company, USA along with all its subsidiaries

DOW CHEMICAL INTERNATIONAL PRIVATE LIMITED,THANE vs. DEPUTY COMMISSIONER OF INCOME TAX - 14(1)(2), MUMBAI

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

depreciation on goodwill. Being aggrieved, the assessee is in appeal before us. 9. We have considered the submissions of both sides and perused the material available on record. Before dealing with submissions of both parties on this issue, it is relevant to note certain basic facts of the present case. Rohm and Hass Company, USA along with all its subsidiaries

GRASIM INDUSTRIES LIMITED,MUMBAI vs. DCIT, CC-1(4), MUMBAI

In the result, appeal of the revenue and the assessee are partly allowed,\nand the additional ground of the assessee is dismissed

depreciation under section 32 of the Act.\n\n53. The Ld. AR has submitted that the issue under consideration has consistently\nbeen decided in its favour by the coordinate benches of the ITAT, Mumbai. In\nparticular, reliance has been placed on the decision of the Tribunal in the assessee's\nown case for the immediately preceding

L & T TECHNOLOGIES SERVICES LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 2(2)(1), MUMBAI

In the result, the additional grounds of the assessee are allowed for statistical purposes

Bench: Shri B.R. Baskaran & Shri Anikesh Banerjeel&T Technologies Services Ltd Vs Assistant Commissioner Of Income L&T House, N.M. Marg, Tax, Circle 2(2)(1), Mumbai Room No.545, 5Th Floor, Aayakar Mumbai Pan: Aaccl4310P Bhavan, Maharshi Karve Road, Mumbai-400 020 Appellant Respondent

391-394 of the Companies Act, 1956. ii. Resulting company i.e. the assessee has not issued any shares inconsideration of the demerger. It is worth noting that consideration has beenactually discharged by way of payment to LTIL for acquisition of theundertaking. 10. The Ld. AR argued that goodwill acquired by the assessee is eligible for depreciation