2018 (6) TMI 1631

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..... the Revenue raises is regarding the permissibility of a claim for deduction made for the first time before the Appellate Tribunal without such claim having been made earlier. It appears that a fresh ground was urged before the Appellate Tribunal by the assessee that it was entitled to depreciation of the goodwill that had been acquired pursuant to the acquisition of a company or a unit or the li .....

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..... e Act to the Appellate Tribunal, a point in such regard could be taken for the first time before the Appellate Tribunal if such point arose as a result of a judicial decision that affected the rights of the assessee during the pendency of the appeal. In view of the aforesaid, there does not appear to be any substantial question of law warranting reconsideration of the Appellate Tribunal's opinion .....

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