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The ITAT upheld the Principal CIT's revision under section 263, ruling that the AO failed to properly scrutinize the depreciation claim on goodwill in AY 2018-19, despite its disallowance in the immediately preceding year. The Tribunal rejected the assessee's contention invoking the principle of consistency, noting that the claim was disallowed previously on identical facts and no new evidence or change in circumstances justified its allowance. The subsequent allowance of depreciation in later years was deemed irrelevant and could not validate an earlier erroneous acceptance. The misclassification of goodwill as a tangible asset further indicated inadequate examination by the AO. Consequently, the revision was confirmed, affirming that the AO should have disallowed the depreciation claim in AY 2018-19, consistent with the prior year's findings. The appeal was dismissed.
The ITAT upheld the Principal CIT's revision under section 263, ruling that the AO failed to properly scrutinize the depreciation claim on goodwill in AY 2018-19, despite its disallowance in the immediately preceding year. The Tribunal rejected the assessee's contention invoking the principle of consistency, noting that the claim was disallowed previously on identical facts and no new evidence or change in circumstances justified its allowance. The subsequent allowance of depreciation in later years was deemed irrelevant and could not validate an earlier erroneous acceptance. The misclassification of goodwill as a tangible asset further indicated inadequate examination by the AO. Consequently, the revision was confirmed, affirming that the AO should have disallowed the depreciation claim in AY 2018-19, consistent with the prior year's findings. The appeal was dismissed.
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