ITAT allowed the assessee's appeal and set aside the PCIT's order u/s 263. It held that the AO had duly inquired into and correctly allowed depreciation on goodwill arising from amalgamation (including Studio 18 and Prism TV) and on the Voot platform, following binding precedent and a legally tenable view where two views were possible; hence the assessment was neither erroneous nor prejudicial to the interests of Revenue, and Explanation 2 to s.263 was inapplicable. The Tribunal further held that once depreciation on goodwill was accepted in the year of capitalization, consistency barred its denial in later years. Alleged errors in determination of carry-forward losses were also held not prejudicial, as revenue impact arises only at set-off.
ITAT allowed the assessee's appeal and set aside the PCIT's order u/s 263. It held that the AO had duly inquired into and correctly allowed depreciation on goodwill arising from amalgamation (including Studio 18 and Prism TV) and on the Voot platform, following binding precedent and a legally tenable view where two views were possible; hence the assessment was neither erroneous nor prejudicial to the interests of Revenue, and Explanation 2 to s.263 was inapplicable. The Tribunal further held that once depreciation on goodwill was accepted in the year of capitalization, consistency barred its denial in later years. Alleged errors in determination of carry-forward losses were also held not prejudicial, as revenue impact arises only at set-off.
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