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    <title>DRP wrongly applied Finance Act 2021 to s.32(1); depreciation, s.28(iv) and TDS disallowances remanded for verification</title>
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    <description>ITAT held that the Dispute Resolution Panel erred in applying the Finance Act 2021 amendment to s.32(1) retrospectively. The issue of depreciation on goodwill/intangible assets acquired under slump sale was remanded to the AO for de novo adjudication after considering additional evidence, without any finding on merits. On addition under s.28(iv) for free-of-cost assets, AO was directed to delete the addition to the extent the assessee-company proves that such assets were re-exported or destroyed as per owners&#039; instructions, after verification. Disallowance under s.40(a)(i) for alleged TDS defaults under ss.194C and 194I was also remanded to AO for fresh decision after examining lower deduction certificates.</description>
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    <pubDate>Tue, 09 Dec 2025 08:41:59 +0530</pubDate>
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      <title>DRP wrongly applied Finance Act 2021 to s.32(1); depreciation, s.28(iv) and TDS disallowances remanded for verification</title>
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      <description>ITAT held that the Dispute Resolution Panel erred in applying the Finance Act 2021 amendment to s.32(1) retrospectively. The issue of depreciation on goodwill/intangible assets acquired under slump sale was remanded to the AO for de novo adjudication after considering additional evidence, without any finding on merits. On addition under s.28(iv) for free-of-cost assets, AO was directed to delete the addition to the extent the assessee-company proves that such assets were re-exported or destroyed as per owners&#039; instructions, after verification. Disallowance under s.40(a)(i) for alleged TDS defaults under ss.194C and 194I was also remanded to AO for fresh decision after examining lower deduction certificates.</description>
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      <pubDate>Tue, 09 Dec 2025 08:41:59 +0530</pubDate>
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