2014 (1) TMI 1856 - HC - Income Tax

Appeal is admitted for consideration of following substantial questions of law - 1. Whether the Appellate Tribunal is right in law and on facts in quashing the re-assessment proceedings holding that the re-opening was because of change of opinion and no new information was brought on record? 2. Whether the Appellate Tribunal is right in law and on facts in holding that the AO had not fulfilled pre-requirement for invoking the provision of explanation fee to section 43(1) of the IT Act and thereby in allowing the full claim of depreciation at ₹ 62.5 crore on intangible assets worth ₹ 500 crore?

Summary

The Gujarat High Court admitted a Tax Appeal for consideration of substantial questions of law related to quashing re-assessment proceedings and allowing depreciation on intangible assets. Key questions include the validity of re-opening due to change of opinion and fulfillment of pre-requisites for invoking IT Act provisions.