Assessee developed intangible assets by incurring expenditure and valued them based on historical cost...

Assessee developed intangible assets by incurring expenditure and valued them based on historical cost as per Accounting Standard (AS)-26, which prescribes cost basis for internally generated intangible assets. Commissioner of Income Tax (CIT) erroneously believed assessee did not follow AS-26 and valuation method was incorrect. Tribunal held assessee's valuation method complied with AS-26, CIT's assumption of jurisdiction u/s 263 was flawed and based on incorrect understanding of AS-26. Regarding depreciation, expenses incurred for intangible assets were genuine business expenses. Disallowing depreciation would result in allowing expenses u/s 37(1), benefiting assessee. CIT did not address assessee's contentions properly. Tribunal set aside CIT's revisionary order as unsustainable in law. .....

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