आदेश/ORDER

PER : T.R. SENTHIL KUMAR, JUDICIAL MEMBER:-

These two appeals are filed by the Revenue as against separate appellate orders dated 20.05.2022 and 08-06-2022 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, (in short referred to as “CIT(A)”), arising out of the assessment orders passed under section143(3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) relating to the Assessment Years 2017-18 and 2018-19 respectively. Since common issue of disallowance of depreciation on Goodwill is involved in both the assessment years, for the sake of convenience the same are disposed of by this common order

2. Brief facts of the case is that the assessee company is engaged in the business of (i) manufacturing of solid Bio-Fuel and Wood Pallet (ii) Trading in solar Rooftop and Renewal Energy Devices (iii) trading in tissue culture plants and (iv) Product Development Services. For the Asst. Year 2017-18, the assessee filed its original return of income declaring Nil total income on 06.11.2017. Thereafter, pursuant to the Composite Scheme of Arrangement (Scheme) approved by Ahmedabad Bench of National Company Law Tribunal (NCLT) vi