आदेश/ORDER

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 in deleting the disallowance of Rs.2,64,14,409/- on account of deprecation on goodwill without appreciating the facts of the case and reasons elaborated by the A.O. in the assessment order."

2) "The Ld. CIT(A) has ignored the intricacies of 6th proviso to section 32(1), section 49(1)(iii)(e), Explanation 7 to section 43(1) and/or Explanation 2(b) to section 43(6)(c) and section 55(2)(a)(ii) which established that Depreciation cannot be claimed on goodwill arising out of amalgamation under the existing provision of the Inc