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    <title>2025 (7) TMI 1155 - ITAT AHMEDABAD</title>
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    <description>The ITAT Ahmedabad ruled in favor of the assessee on two issues. First, regarding revision u/s 263, the PCIT erred in finding the assessment order erroneous for failure to deduct tax on provisional expenses. The tribunal held that provisional expenses created under mercantile accounting system as mandated by Income Tax Act and Companies Act were properly reversed on the first day of next financial year, negating any TDS liability. Second, concerning depreciation on intangible assets with nil acquisition cost, following Man Industries precedent, the tribunal allowed depreciation claims as TDS liability paid on premium became inseparable part of block asset after merger, losing individual identity for depreciation calculation purposes. Both appeals were decided in assessee&#039;s favor.</description>
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    <pubDate>Thu, 29 May 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=775087</link>
      <description>The ITAT Ahmedabad ruled in favor of the assessee on two issues. First, regarding revision u/s 263, the PCIT erred in finding the assessment order erroneous for failure to deduct tax on provisional expenses. The tribunal held that provisional expenses created under mercantile accounting system as mandated by Income Tax Act and Companies Act were properly reversed on the first day of next financial year, negating any TDS liability. Second, concerning depreciation on intangible assets with nil acquisition cost, following Man Industries precedent, the tribunal allowed depreciation claims as TDS liability paid on premium became inseparable part of block asset after merger, losing individual identity for depreciation calculation purposes. Both appeals were decided in assessee&#039;s favor.</description>
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