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IN THE INCOME TAX APPELLATE TRIBUNAL

DELHI BENCH ‘E’, NEW DELHI

BEFORE SH. SATBEER SINGH GODARA, JUDICIAL MEMBER

AND

SH. NAVEEN CHANDRA, ACCOUNTANT MEMBER

ITA Nos. 7771 & 7772/Del/2025

(Assessment Years : 2020-21 & 2021-22)

Uno Minda Limited Vs. DCIT

(Successor to Harita Fehrer Central Circle – 13,

Ltd.) Delhi

B-64/1, Wazirpur Industrial

Area

Delhi – 110 052

PAN No. AAACM 1152 C

(APPELLANT) (RESPONDENT)

Assessee by Shri Ravi Kumar, C.A. and

Ms. Sakshi Goyal, C.A.

Revenue by Ms. Ankush Kalra, Sr. D.R.

Date of hearing: 27.04.2026

Date of Pronouncement: 18.05.2026

ORDER

PER NAVEEN CHANDRA, ACCOUNTANT MEMBER :

Both the captioned appeals have been filed by the assessee

against the order of the learned The Commissioner of Income-Tax

(Appeal)-Delhi-26 [‘CIT(A)’ in short] dated 04.09.2025 under section

250 of the Income Tax Act, 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.

ITA Nos. 7771 & 7772/DEL/2025

[A.Y 2020-21 & 2021-22]

UNO Minda Ltd. vs. DCIT

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 declaring total income

of Rs.26,70,04,520/-. The case of the assessee was selected for

'complete scrutiny' under Computer Aided Scrutiny Selection (CASS),

under the E-assessment Scheme, 2019. Subsequently, the assessment

proceedings u/s 143(3) r.w.s. 144B of the Income Tax Act, 1961 were

completed at assessed income of Rs.27,43,97,208/-, with disallowance

of (i) Rs. 30,54,000/- on account of depreciation of non-compete fees,

u/s 32 of Act and (ii) Rs. 43,38,688/- on account of Health and

Education Cess, u/s 40(a)(ii) of Act. Upon appeal, the CIT(A) dismissed

the appeal of the assessee. Aggrieved by the order of CIT(A), assessee

is now before the Tribunal with the following grounds:

1. That the order of Ld. CIT(A) u/s 250 of the Income-tax Act, 1961 (‘the Act')

is bad in law and on the facts of the Assessee Company.

Page 2 of 6

ITA Nos. 7771 & 7772/DEL/2025

[A.Y 2020-21 & 2021-22]

UNO Minda Ltd. vs. DCIT

2. That the Ld. AO and consequently the Ld. CIT(A) erred in law, on facts and

in the circumstances of the assessee's case in not allowing the Depreciation

on Non-Compete Fees claimed u/s 32(1)(ii) of the Act by holding that the

said expenditure does not qualify for depreciation under said section of the

Act, despite of already being capitalized and accepted during the

Assessment for A.Y. 2010-11.

3. That the Ld. CIT(A) grossly erred in law in not following the binding nature

of orders of Hon'ble ITAT in Assessee's own case for A.Y. 2011-12, A.Y. 2013-

14, A.Y. 2014-15 & A.Y. 2016-17 on the identical facts arising from 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 allowed to it and the appellant may also be allowed to add,

delete, amend or substitute any ground(s) of appeal either at or before the

date of hearing.”

4. The main iss