<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>2025 (7) TMI 1288 - ITAT AHMEDABAD</title>
    <link>https://www.taxtmi.com/caselaws?id=775220</link>
    <description>ITAT Ahmedabad dismissed revenue appeals across multiple issues. The assessee successfully claimed depreciation on goodwill arising from court-sanctioned amalgamation, as the goodwill represented genuine arm&#039;s length acquisition recorded per approved scheme and qualified as identifiable intangible asset under section 32(1)(ii). The tribunal allowed carry-forward of unabsorbed depreciation, ruling that once depreciation is accepted initially, carry-forward becomes vested right that cannot be denied without appellate reversal. Product registration expenses were treated as revenue expenditure under section 37(1), being mandatory compliance costs rather than capital asset acquisition. Full section 80IC deduction was upheld for the eligible unit, rejecting revenue&#039;s attempt to allocate corporate expenses without establishing proximate nexus. Scrap income from manufacturing byproducts qualified for 80IC deduction as integral business receipts. Enhanced profits from section 40(a)(ia) disallowances also qualified for 80IC deduction per CBDT circular and binding precedent.</description>
    <language>en-us</language>
    <pubDate>Wed, 16 Jul 2025 00:00:00 +0530</pubDate>
    <lastBuildDate>Tue, 22 Jul 2025 08:25:25 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=837718" rel="self" type="application/rss+xml"/>
    <item>
      <title>2025 (7) TMI 1288 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=775220</link>
      <description>ITAT Ahmedabad dismissed revenue appeals across multiple issues. The assessee successfully claimed depreciation on goodwill arising from court-sanctioned amalgamation, as the goodwill represented genuine arm&#039;s length acquisition recorded per approved scheme and qualified as identifiable intangible asset under section 32(1)(ii). The tribunal allowed carry-forward of unabsorbed depreciation, ruling that once depreciation is accepted initially, carry-forward becomes vested right that cannot be denied without appellate reversal. Product registration expenses were treated as revenue expenditure under section 37(1), being mandatory compliance costs rather than capital asset acquisition. Full section 80IC deduction was upheld for the eligible unit, rejecting revenue&#039;s attempt to allocate corporate expenses without establishing proximate nexus. Scrap income from manufacturing byproducts qualified for 80IC deduction as integral business receipts. Enhanced profits from section 40(a)(ia) disallowances also qualified for 80IC deduction per CBDT circular and binding precedent.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Wed, 16 Jul 2025 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=775220</guid>
    </item>
  </channel>
</rss>