Back
INCOME TAX APPELLATE TRIBUNAL (AHMEDABAD BENCH)
Sanjay Garg, Judicial Member
Revenue – Appellant
Versus
Unicorn Packaging LLP – Respondent
| Table of Content |
|---|
| 1. corporate restructuring via amalgamations and conversion to llp (Para 1 , 3) |
| 2. depreciation allowable on amalgamation goodwill as intangible asset (Para 2 , 4 , 5) |
| 3. revenue appeals dismissed following prior bindings precedents (Para 6 , 7 , 9 , 13 , 20 , 21 , 22) |
| 4. section 148 notice time-barred under tola and ashish agarwal (Para 8) |
| 5. assessment invalid in name of non-existing converted entity (Para 10 , 11 , 12) |
| 6. no 14a disallowance without recorded dissatisfaction before rule 8d (Para 14 , 15 , 16 , 17 , 18) |
Per Sanjay Garg, Judicial Member:
The captioned appeals have been preferred by the Revenue against the separate orders of the learned Commissioner of Income Tax (Appeals)-11, Ahmedabad [hereinafter referred to as “(CIT(A)”] Since identical facts and issues are involved in these appeals, hence the same were heard together and are being disposed of by this common order. ITA No.893/Ahd/2025 preferred against the order of the CIT(A) dated 24.02.2025 for the assessment year 2016-17 is taken as the lead case for the purpose of narration of facts.
ITA 893/AHD/2025:
2. The Revenue in this appeal has taken the following Grounds of Appeal:
1) "The Ld. CIT(A) has erred
An indispensable Tool for Legal Professionals, Endorsed by Various High Court and Judicial Officers
Please visit our Training & Support
Center or Contact Us for assistance
Scan Me!
India’s Legal research and Law Firm App, Download now!
For Daily Legal Updates, Join us on :
Back to top
