https://www.taxtmi.com/caselaws?id=765967 Gujarat HC quashed reassessment notice u/s 148 and order u/s 147 regarding depreciation on written down value of goodwill. AO failed to consider ITAT order showing deletion of addition made on DRP recommendation under Section 92BA, which was not applicable for the assessment year. Since ITAT's non-consideration of merits cannot constitute information for assuming jurisdiction under Section 148, and AO failed to demonstrate effect of deletion from AY 2014-15, no income escapement existed for AY 2018-19. Petition allowed in favor of assessee. en-us Tue, 04 Feb 2025 00:00:00 +0530 Fri, 27 Feb 2026 12:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=765967 Gujarat HC quashed reassessment notice u/s 148 and order u/s 147 regarding depreciation on written down value of goodwill. AO failed to consider ITAT order showing deletion of addition made on DRP recommendation under Section 92BA, which was not applicable for the assessment year. Since ITAT's non-consideration of merits cannot constitute information for assuming jurisdiction under Section 148, and AO failed to demonstrate effect of deletion from AY 2014-15, no income escapement existed for AY 2018-19. Petition allowed in favor of assessee. Case-Laws Income Tax Tue, 04 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=765967