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ITAT held that the Dispute Resolution Panel erred in applying the Finance Act 2021 amendment to s.32(1) retrospectively. The issue of depreciation on goodwill/intangible assets acquired under slump sale was remanded to the AO for de novo adjudication after considering additional evidence, without any finding on merits. On addition under s.28(iv) for free-of-cost assets, AO was directed to delete the addition to the extent the assessee-company proves that such assets were re-exported or destroyed as per owners' instructions, after verification. Disallowance under s.40(a)(i) for alleged TDS defaults under ss.194C and 194I was also remanded to AO for fresh decision after examining lower deduction certificates.
ITAT held that the Dispute Resolution Panel erred in applying the Finance Act 2021 amendment to s.32(1) retrospectively. The issue of depreciation on goodwill/intangible assets acquired under slump sale was remanded to the AO for de novo adjudication after considering additional evidence, without any finding on merits. On addition under s.28(iv) for free-of-cost assets, AO was directed to delete the addition to the extent the assessee-company proves that such assets were re-exported or destroyed as per owners' instructions, after verification. Disallowance under s.40(a)(i) for alleged TDS defaults under ss.194C and 194I was also remanded to AO for fresh decision after examining lower deduction certificates.
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