2016 (4) TMI 1193

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..... ent appeal has been preferred by the assessee against the order dated 13.08.2012 of the Commissioner of Income Tax (Appeals) [hereinafter referred to as the CIT(A)] relevant to assessment year 2005-06. 2. The assessee has taken two effective grounds of appeal. Ground No.1 3. The ground No.1 is relating to the disallowance on account of depreciation on brands under section 32(1)(ii) of the Incom .....

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..... relied upon by the Ld. D.R. also, in para 23 of the order has held that franchising is kind of business where franchiser grants a license to franchisee to use franchisor's intellectual property rights such as knowhow, trade marks, brand name etc. to market the franchisor's product or services for consideration. The Hon'ble Bombay High Court has held that the expression 'Licenses' is a very wide te .....

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..... isallowing the claim of depreciation on the brands for the year under consideration. This issue is accordingly decided in favour of the assessee. Ground No.2 5. Vide ground No.2, the assessee has agitated the disallowance and consequential addition of an amount of Rs. 3,28,00,000/- in respect of contingent liabilities. 6. At the outset, the Ld. A.R. has brought our attention to the opening line .....

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