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ITAT ruled in favor of assessee, setting aside revision under s.263 regarding goodwill depreciation claim post-amalgamation. The tribunal found PCIT's jurisdiction exercise erroneous, as evidence clearly showed trade receivables of Municipal Waste Division were never transferred to assessee under NCLT-approved amalgamation scheme. The AO had conducted detailed inquiry regarding goodwill depreciation during assessment proceedings. ITAT determined PCIT's revision was based on misconceived facts and incorrect assumption about transfer of trade receivables, making the s.263 revision order legally unsustainable. The assessee had provided comprehensive documentation including board resolutions and scheme details supporting their position.
ITAT ruled in favor of assessee, setting aside revision under s.263 regarding goodwill depreciation claim post-amalgamation. The tribunal found PCIT's jurisdiction exercise erroneous, as evidence clearly showed trade receivables of Municipal Waste Division were never transferred to assessee under NCLT-approved amalgamation scheme. The AO had conducted detailed inquiry regarding goodwill depreciation during assessment proceedings. ITAT determined PCIT's revision was based on misconceived facts and incorrect assumption about transfer of trade receivables, making the s.263 revision order legally unsustainable. The assessee had provided comprehensive documentation including board resolutions and scheme details supporting their position.
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