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    <title>2025 (8) TMI 517 - ITAT COCHIN</title>
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    <description>The ITAT Cochin held that the revaluation of software did not constitute a transfer under section 47(xiii), as no actual sale or transfer occurred, and the increase in closing stock value was merely a book entry. The addition made by the AO was deleted. Depreciation disallowance was set aside, directing the AO to verify and allow depreciation as per section 32(1) proviso since the assessee furnished necessary details. The reopening of assessment under section 43B was quashed due to lack of valid reasons and contradictions in the recorded reasons. The CIT(A)&#039;s confirmation of reopening without reasons was held invalid. Grounds relating to reopening and additions based on such reopening were disallowed.</description>
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      <title>2025 (8) TMI 517 - ITAT COCHIN</title>
      <link>https://www.taxtmi.com/caselaws?id=776330</link>
      <description>The ITAT Cochin held that the revaluation of software did not constitute a transfer under section 47(xiii), as no actual sale or transfer occurred, and the increase in closing stock value was merely a book entry. The addition made by the AO was deleted. Depreciation disallowance was set aside, directing the AO to verify and allow depreciation as per section 32(1) proviso since the assessee furnished necessary details. The reopening of assessment under section 43B was quashed due to lack of valid reasons and contradictions in the recorded reasons. The CIT(A)&#039;s confirmation of reopening without reasons was held invalid. Grounds relating to reopening and additions based on such reopening were disallowed.</description>
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      <pubDate>Fri, 03 Jan 2025 00:00:00 +0530</pubDate>
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