https://www.taxtmi.com/caselaws?id=207296 The Tribunal ruled in favor of the assessee on both issues. Firstly, it held that the Assessing Officer's reopening of proceedings under section 148 was unjustified as it constituted a mere change of opinion, contrary to legal provisions. Consequently, the assessment was quashed. Secondly, the Tribunal upheld the assessee's claim for depreciation on intangible assets, emphasizing that the payment made was for specific commercial rights, not goodwill. The Tribunal rejected attempts to disallow the claim through subsequent notices, ultimately allowing the appeal and affirming the depreciation claim on intangible assets. en-us Fri, 03 Dec 2010 00:00:00 +0530 Wed, 07 Dec 2011 01:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207296 The Tribunal ruled in favor of the assessee on both issues. Firstly, it held that the Assessing Officer's reopening of proceedings under section 148 was unjustified as it constituted a mere change of opinion, contrary to legal provisions. Consequently, the assessment was quashed. Secondly, the Tribunal upheld the assessee's claim for depreciation on intangible assets, emphasizing that the payment made was for specific commercial rights, not goodwill. The Tribunal rejected attempts to disallow the claim through subsequent notices, ultimately allowing the appeal and affirming the depreciation claim on intangible assets. Case-Laws Income Tax Fri, 03 Dec 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207296