Intangible Asset Depreciation Claim Upheld: Reasonable Approach Validates Tax Assessment Under Section 263

ITAT adjudicated a tax dispute regarding depreciation claim on intangible assets. The tribunal held that the assessee's depreciation claim on intangible assets under development was legally sustainable. The court emphasized that not every revenue loss constitutes prejudice to revenue interests. Citing SC precedents, the tribunal confirmed that when an AO adopts a permissible approach and takes a reasonable view, the assessment cannot be considered erroneous. The tribunal quashed the CIT's order under Section 263, ruling that the depreciation claim on goodwill was allowable and did not cause revenue prejudice. Consequently, the assessee's appeal grounds were fully allowed, maintaining the original depreciation claim. .....

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