2026 (5) TMI 1141

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....1961 ('the Act') arising from the orders dated 21.10.2022 and 22.12.2022 passed by Assessment Unit (herein refereed as 'the Assessing Officer or AO') under section 143(3) r.w.s. 144B of the Act concerning Assessment Years (A.Ys.) 2020-21 & 2021- 22. 2. Since the above captioned appeals were heard together and the facts in issues are identical, both the appeals are being disposed of by this common order for the sake of convenience and brevity. ITA No.7771/Del/2025 for A.Y. 2020-21 : 3. Briefly stated the facts of the case as culled out that the assessee is a subsidiary to Harita Fehrer Limited which was now merged with Uno Minda Ltd. (herein referred as the 'assessee') and filed its original return of income on 14.11.2021 de....

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....rom the same transaction. 4. That the Ld. CIT(A) erred in law and facts in confirming the disallowance made by the Ld. AO of Rs. 30,54,000/- on account of depreciation u/s 32(1)(ii) on Non-Compete Fees, by overlooking the fact that the actual amount of depreciation of Rs. 8,09,507/- was claimed on such class of Intangible Assets. Others 5. The aforesaid grounds of appeal are without prejudice to one another. 6. The appellant craves leave to add, amend, alter, change, vary or substitute any of the aforesaid grounds or raise an additional ground if it becomes necessary to do so in the interest of justice. PRAYER The appellant prays that the relief as per grounds of appeal above may kindly be all....