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2019 (7) TMI 25 - ITAT BANGALOREDepreciation on Goodwill - depreciation on Customer Relationship (CR) & Vendor Relationship (VR) considering them to fall under Any other business or commercial rights of similar nature - treatment as asset under Explanation 3(b) to Section 32(1) - impact of non claiming in return of income - HELD THAT:- As decided in SMIFS SECURITIES LTD. [2012 (8) TMI 713 - SUPREME COURT] Explanation 3 states that the expression 'asset' shall mean an intangible asset, being know-how, patents, copyrights, trademarks, licences, franchises or any other business or commercial rights of similar nature. A reading the words 'any other business or commercial rights of similar nature' in clause (b) of Explanation 3 indicates that goodwill would fall under the expression 'any other business or commercial right of a similar nature'. The principle of ejusdem generis would strictly apply while interpreting the said expression which finds place in Explanation 3(b). In the circumstances, we are of the view that 'Goodwill' is an asset under Explanation 3(b) to Section 32(1) - Decided against revenue
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