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“depreciation on goodwill”

DepreciationSection 32Section 32346 judgments

COROMANDEL INTERNATIONAL LIMITED,HYDERABAD vs. DCIT., CIRCLE-2(2), HYDERABAD

In the result the appeal of the assessee is partly allowed for statistical purposes

ITA 738/HYD/2025[2015-2016]Status: DisposedITAT Hyderabad18 Mar 2026AY 2015-2016

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआयकर अपीलसं./I.T.A. No.738/Hyd/2025 ("नधा"रणवष"/ Assessment Year:2015-16) Coromandel International Vs. Dcit, Limited, Circle-2(2), Hyderabad. Hyderabad. Pan: Aaacc7852K (अपीलाथ"/ Appellant) (""यथ"/ Respondent) करदाताका""त"न"ध"व/ : Shri Sp Chidambaram, Advocate Assessee Represented By राज"वका""त"न"ध"व/ : Ms. U. Mini Chandran, Cit-Dr Department Represented By सुनवाईसमा"तहोनेक""त"थ/ : 02/03/2026 Date Of Conclusion Of Hearing घोषणा क" तार"ख/ : 18/03/2026 Date Of Pronouncement Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Coromandel International Limited (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) Dated 24/02/2025 For The Assessment Year (“A.Y.”) 2015-16. Page 1 Of 17 Coromandel International Limited Vs. Dcit 2. The Assessee Has Raised The Following Grounds Of Appeal:

Section 250Section 32Section 32(1)(ii)Section 35

which had allowed the Appellant to furnish response within 10 days from the date of receipt of issue letter. 2. Non-grant of depreciation on goodwill on amalgamation a. The Ld. CIT has grossly erred in law and on facts in denying the Appellant's claim for depreciation on goodwill ... been claimed and allowed, irrespective of whether it is actually claimed by the Assessee in the return of income. d. The denial of depreciation on goodwill, being a recognized depreciable intangible asset under Section 32(1)(ii), on account of a procedural lapse, is in clear contravention of statutory provisions

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 898/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2020-21

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

Assessing Officer disallowed the said claim solely on the ground that, in the case of the predecessor company, Urmin Marketing Pvt. Ltd., depreciation on goodwill created on account of amalgamation had been disallowed for A.Y. 2015-16 by the Assessing Officer, and that the same position should continue ... known as Unicorn Packaging LLP) for A.Y. 2015-16 in ITA No.1806/Ahd/2019, wherein the Tribunal had allowed the claim of depreciation on goodwill. The assessee also brought to the notice of the learned CIT(A) that, in the appellate order in the case of Unicorn Packaging

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD, AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 897/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2018-19

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

Assessing Officer disallowed the said claim solely on the ground that, in the case of the predecessor company, Urmin Marketing Pvt. Ltd., depreciation on goodwill created on account of amalgamation had been disallowed for A.Y. 2015-16 by the Assessing Officer, and that the same position should continue ... known as Unicorn Packaging LLP) for A.Y. 2015-16 in ITA No.1806/Ahd/2019, wherein the Tribunal had allowed the claim of depreciation on goodwill. The assessee also brought to the notice of the learned CIT(A) that, in the appellate order in the case of Unicorn Packaging

ACIT CC-1(3), AHMEDABAD, AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 896/AHD/2025[2017-18]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2017-18

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

Assessing Officer disallowed the said claim solely on the ground that, in the case of the predecessor company, Urmin Marketing Pvt. Ltd., depreciation on goodwill created on account of amalgamation had been disallowed for A.Y. 2015-16 by the Assessing Officer, and that the same position should continue ... known as Unicorn Packaging LLP) for A.Y. 2015-16 in ITA No.1806/Ahd/2019, wherein the Tribunal had allowed the claim of depreciation on goodwill. The assessee also brought to the notice of the learned CIT(A) that, in the appellate order in the case of Unicorn Packaging

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING PRIVATE LIMITED, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 895/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

Assessing Officer disallowed the said claim solely on the ground that, in the case of the predecessor company, Urmin Marketing Pvt. Ltd., depreciation on goodwill created on account of amalgamation had been disallowed for A.Y. 2015-16 by the Assessing Officer, and that the same position should continue ... known as Unicorn Packaging LLP) for A.Y. 2015-16 in ITA No.1806/Ahd/2019, wherein the Tribunal had allowed the claim of depreciation on goodwill. The assessee also brought to the notice of the learned CIT(A) that, in the appellate order in the case of Unicorn Packaging

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 894/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

Assessing Officer disallowed the said claim solely on the ground that, in the case of the predecessor company, Urmin Marketing Pvt. Ltd., depreciation on goodwill created on account of amalgamation had been disallowed for A.Y. 2015-16 by the Assessing Officer, and that the same position should continue ... known as Unicorn Packaging LLP) for A.Y. 2015-16 in ITA No.1806/Ahd/2019, wherein the Tribunal had allowed the claim of depreciation on goodwill. The assessee also brought to the notice of the learned CIT(A) that, in the appellate order in the case of Unicorn Packaging

ACIT CENTRAL CIRCLE 1(3), AHMEDABAD vs. UNICORN PACKAGING LLP, AHMEDABAD

In the result, this appeal of the Revenue is, accordingly, stands dismissed

ITA 893/AHD/2025[2016-17]Status: DisposedITAT Ahmedabad25 Feb 2026AY 2016-17

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं/ िनधा"रण वष"/ Sl. Appeal(S) By :

For Appellant: Shri Aseem L. Thakkar, ARFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 32(1)Section 43(1)Section 43(6)(c)Section 49(1)(iii)Section 55(2)(a)

Assessing Officer disallowed the said claim solely on the ground that, in the case of the predecessor company, Urmin Marketing Pvt. Ltd., depreciation on goodwill created on account of amalgamation had been disallowed for A.Y. 2015-16 by the Assessing Officer, and that the same position should continue ... known as Unicorn Packaging LLP) for A.Y. 2015-16 in ITA No.1806/Ahd/2019, wherein the Tribunal had allowed the claim of depreciation on goodwill. The assessee also brought to the notice of the learned CIT(A) that, in the appellate order in the case of Unicorn Packaging

ACIT CENTRAL CIRCLE 2(3), AHMEDABAD vs. INTAS PHARMACEUTICALS LIMITED, AHMEDABAD

In the result, the appeal of the Revenue is dismissed

ITA 1842/AHD/2024[2016-17]Status: DisposedITAT Ahmedabad24 Feb 2026AY 2016-17

Bench: Ms. Suchitra R. Kamble & Shri Narendra Prasad Sinhaasst. Commissioner Of M/S. Intas Pharmaceuticals Ltd., Vs. Income-Tax, Corporate House, S.G. Highway, Central Circle 2(3), Nr. Sola Bridge, Thaltej, Ahmedabad Ahmedabad-380 054 [Pan : Aaaci 5120 L] (Appellant) .. (Respondent) Appellant Represented By : Shri Sher Singh, Cit (Dr) Respondent Represented By: Shri S. N. Soparkar, Sr. Advocate & Ms. Urvashi Sodhan, Ar Date Of Hearing 07.01.2026 Date Of Pronouncement 24.02.2026 O R D E R Per Ms. Suchitra R. Kamble:-

Section 250

erred in deleting the addition of Rs. 170,94,37,500/- made on account of depreciation on Goodwill disallowed by the AO, without appreciating the fact that, DCF method adapted in the valuation report to value equity of M/s Intas Lifesciences Pvt. Ltd., was not the appropriate method of valuation ... Ground Nos. 3 & 4 raised by the Revenue are dismissed. Ground No.5. 6. General Ground. No specific adjudication required. Ground Nos. 6 & 12 –Depreciation on Goodwill arising pursuant to Amalgamation 7. These grounds relate to the deletion of addition made by the Assessing Officer on account of depreciation claimed

RUBBER KING TYRE PRIVATE LIMITED,AHMEDABAD , GUJARAT vs. DCIT,3(1)(2), AHMEDABAD , GUJARAT

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 145/AHD/2026[2017-18]Status: DisposedITAT Ahmedabad20 Feb 2026AY 2017-18

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years: 2017-18

Section 143(3)Section 32Section 32(1)Section 43(1)Section 43(6)

Commissioner of Income tax (Appeals) National Faceless Appeal Centre (NFAC), Delhi has erred in confirming the action of the Assessing Officer in disallowing depreciation on goodwill amounting to Rs.3.31,62,509/-on irrelevant grounds. The disallowance has been made wrongly by invoking Explanation-7 to section 43(1) and/or Explanation ... Commissioner of Income tax (Appeals) National Faceless Appeal Centre (NFAC), Delhi has erred in confirming the action of the Assessing Officer in disallowing depreciation on goodwill acquired for cost by wrongly interpreting the various provisions of law and not following the binding judgments including those of Honble Apex Court

AMMANN INDIA PRIVATE LIMITED,MEHSANA vs. THE PR. CIT-3, AHMEDABAD

In the result, the appeal of the assessee is allowed

ITA 1536/AHD/2025[2020-21]Status: DisposedITAT Ahmedabad05 Feb 2026AY 2020-21

Bench: Shri Tr Senthil Kumar & Shri Narendra Prasad Sinhaassessment Years: 2020-21

Section 143(3)Section 144BSection 263

Revenue without satisfying the twin conditions required under section 263 of the Act. 2. Erroneous Observations on Goodwill and incorrect disallowance of depreciation on Goodwill 2.1 On the facts and in the circumstances of the case and in law, the Ld. PCIT has erred in disregarding the bona fide nature ... business transactions. 2.2 On the facts and in the circumstances of the case and in law, the Ld. PCIT has erred in disallowing depreciation on goodwill amounting to ₹7,47,78,417, whereas the actual depreciation claimed by the Appellant in the return of income

TRENT LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX 2(3)(1), MUMBAI

In the result, the appeal filed by the assessee is allowed

ITA 5165/MUM/2025[2018-19]Status: DisposedITAT Mumbai05 Feb 2026AY 2018-19
Section 115JSection 142(1)Section 143(3)Section 144BSection 2(11)Section 250Section 32Section 32(1)Section 32(1)(ii)

issues examined by the Assessing Officer in the assessment order relates to the claim of depreciation on goodwill under section 32(1)(ii) of the Act. During the year under consideration, the assessee acquired the 'value fashion' business segment from its group company, namely Trent Hypermarket Private Limited, with effect ... both tangible and intangible, and the liabilities pertaining to the said business segment were transferred to the assessee company.\n4. The assessee claimed depreciation on goodwill acquired as part of the slump sale and added the same to the block of intangible assets during the year. The Assessing Officer required

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

ITA 294/BANG/2025[2021-22]Status: DisposedITAT Bangalore30 Jan 2026AY 2021-22
For Appellant: \nShri Padamchand Kincha, CAFor Respondent: \nShri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

goodwill from trademark or to allege inflation\nof value is contrary to settled law. Further, the amendment made by\nFinance Act, 2021 denying depreciation on goodwill is prospectively and\ntherefore, it establishes that depreciation on goodwill was allowable for\nall earlier years.\n24.13 The assessee also submitted that the lower ... ndepreciation under section 32(1)(ii) of the Act. It was also noted that the\namendment introduced by the Finance Act, 2021 denying depreciation\non goodwill is prospective and applicable only from assessment year\n2021-22 onwards. Accordingly, for the year under consideration,\ngoodwill is eligible for depreciation on merits

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 293/BANG/2025[2020-21]Status: DisposedITAT Bangalore30 Jan 2026AY 2020-21

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

goodwill from trademark or to allege inflation of value is contrary to settled law. Further, the amendment made by Finance Act, 2021 denying depreciation on goodwill is prospectively and therefore, it establishes that depreciation on goodwill was allowable for all earlier years. 24.13 The assessee also submitted that the lower ... depreciation under section 32(1)(ii) of the Act. It was also noted that the amendment introduced by the Finance Act, 2021 denying depreciation on goodwill is prospective and applicable only from assessment year 2021-22 onwards. Accordingly, for the year under consideration, goodwill is eligible for depreciation on merits

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 292/BANG/2025[2019-20]Status: DisposedITAT Bangalore30 Jan 2026AY 2019-20

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

goodwill from trademark or to allege inflation of value is contrary to settled law. Further, the amendment made by Finance Act, 2021 denying depreciation on goodwill is prospectively and therefore, it establishes that depreciation on goodwill was allowable for all earlier years. 24.13 The assessee also submitted that the lower ... depreciation under section 32(1)(ii) of the Act. It was also noted that the amendment introduced by the Finance Act, 2021 denying depreciation on goodwill is prospective and applicable only from assessment year 2021-22 onwards. Accordingly, for the year under consideration, goodwill is eligible for depreciation on merits

EDGEVERVE SYSTEMS LIMITED,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

ITA 291/BANG/2025[2018-19]Status: DisposedITAT Bangalore30 Jan 2026AY 2018-19
For Appellant: \nShri Padamchand Kincha, CAFor Respondent: \nShri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

goodwill from trademark or to allege inflation\nof value is contrary to settled law. Further, the amendment made by\nFinance Act, 2021 denying depreciation on goodwill is prospectively and\ntherefore, it establishes that depreciation on goodwill was allowable for\nall earlier years.\n24.13 The assessee also submitted that the lower ... ndepreciation under section 32(1)(ii) of the Act. It was also noted that the\namendment introduced by the Finance Act, 2021 denying depreciation\non goodwill is prospective and applicable only from assessment year\n2021-22 onwards. Accordingly, for the year under consideration,\ngoodwill is eligible for depreciation on merits

EDGEVERVE SYSTEMS LIMITED ,BANGALORE vs. ACIT, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are partly allowed for statistical purposes

ITA 290/BANG/2025[2017-18]Status: DisposedITAT Bangalore30 Jan 2026AY 2017-18

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Padamchand Kincha, CAFor Respondent: Shri Shivanad Kalakeri, CIT (DR)
Section 250Section 254Section 37Section 90

goodwill from trademark or to allege inflation of value is contrary to settled law. Further, the amendment made by Finance Act, 2021 denying depreciation on goodwill is prospectively and therefore, it establishes that depreciation on goodwill was allowable for all earlier years. 24.13 The assessee also submitted that the lower ... depreciation under section 32(1)(ii) of the Act. It was also noted that the amendment introduced by the Finance Act, 2021 denying depreciation on goodwill is prospective and applicable only from assessment year 2021-22 onwards. Accordingly, for the year under consideration, goodwill is eligible for depreciation on merits

KOVALAM RESORT PRIVATE LIMITED ,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX 2(1)(1), MUMBAI

In the result, the appeal of the assessee for Assessment Year

ITA 6580/MUM/2025[2012-13]Status: DisposedITAT Mumbai30 Jan 2026AY 2012-13

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokar1. Ita No. 6580/Mum/2025 (Assessment Year: 2012-13) 2. Ita No. 6578/Mum/2025 (Assessment Year: 2013-14) & 3. Ita No. 6579/Mum/2025 (Assessment Year: 2014-15) Kovalam Resort Private Dcit 2(1)(1), Limited 561, Aayakar The Leela, Sahar, Andheri Vs. Bhavan, M. K. East, Mumbai-400 059 Road, Mumbai- 400 020 Pan/Gir No. Aaeck4804H (Applicant) (Respondent) Assessee By Shri Dharan Gandi & Shri Ravi Gupta, Ld. Ars Revenue By Shri Ritesh Misra, Ld. Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 30.01.2026

Section 115JSection 142(1)Section 143(1)Section 143(2)Section 143(3)

fully acceptable. He, therefore, rejected the assessee’s claim for depreciation based on its valuation and also rejected the alternative claim for depreciation on goodwill. The learned CIT(A) upheld the action of the Assessing Officer in restricting depreciation to the amount computed on the basis of the written down ... hands of the assessee on acquisition of an undertaking by way of slump sale, and, in the alternative, the allowability of depreciation on goodwill arising as a balancing figure. 39. At the outset, there is no dispute on the following foundational facts that the assessee acquired the Kovalam hotel undertaking

KOVALAM RESORT PRIVATE LIMTIED ,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX 2(1)(1), MUMBAI

In the result, the appeal of the assessee for Assessment Year

ITA 6579/MUM/2025[2014-15]Status: DisposedITAT Mumbai30 Jan 2026AY 2014-15

Bench: Shri Anikesh Banerjee & Shri Makarand Vasant Mahadeokar1. Ita No. 6580/Mum/2025 (Assessment Year: 2012-13) 2. Ita No. 6578/Mum/2025 (Assessment Year: 2013-14) & 3. Ita No. 6579/Mum/2025 (Assessment Year: 2014-15) Kovalam Resort Private Dcit 2(1)(1), Limited 561, Aayakar The Leela, Sahar, Andheri Vs. Bhavan, M. K. East, Mumbai-400 059 Road, Mumbai- 400 020 Pan/Gir No. Aaeck4804H (Applicant) (Respondent) Assessee By Shri Dharan Gandi & Shri Ravi Gupta, Ld. Ars Revenue By Shri Ritesh Misra, Ld. Dr Date Of Hearing 22.01.2026 Date Of Pronouncement 30.01.2026

Section 115JSection 142(1)Section 143(1)Section 143(2)Section 143(3)

fully acceptable. He, therefore, rejected the assessee’s claim for depreciation based on its valuation and also rejected the alternative claim for depreciation on goodwill. The learned CIT(A) upheld the action of the Assessing Officer in restricting depreciation to the amount computed on the basis of the written down ... hands of the assessee on acquisition of an undertaking by way of slump sale, and, in the alternative, the allowability of depreciation on goodwill arising as a balancing figure. 39. At the outset, there is no dispute on the following foundational facts that the assessee acquired the Kovalam hotel undertaking

KOVALAM RESORT PRIVATE LIMITED ,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX 2(1)(1), MUMBAI

ITA 6578/MUM/2025[2013-14]Status: DisposedITAT Mumbai30 Jan 2026AY 2013-14
Section 115JSection 142(1)Section 143(1)Section 143(2)Section 143(3)

fully acceptable. He, therefore, rejected the\nassessee's claim for depreciation based on its valuation and also\nrejected the alternative claim for depreciation on goodwill. The\nlearned CIT(A) upheld the action of the Assessing Officer in\nrestricting depreciation to the amount computed on the basis of\nthe written down ... hands of the\nassessee on acquisition of an undertaking by way of slump sale,\nand, in the alternative, the allowability of depreciation on goodwill\narising as a balancing figure.\n39. At the outset, there is no dispute on the following\nfoundational facts that the assessee acquired the Kovalam hotel\nundertaking

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 14(1)(2), MUMBAI vs. LIGHTHOUSE LEARNING PRIVATE LIMITED, MUMBAI

In the result, the appeal filed by the revenue stands dismissed

ITA 5433/MUM/2024[2020-21]Status: DisposedITAT Mumbai30 Jan 2026AY 2020-21

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

Section 14ASection 250Section 32(1)Section 32(1)(ii)Section 43(1)Section 43(6)

within the meaning of section 32(1) of the Income Tax Act, 1961 and the issue of valuation of goodwill and allowability of depreciation on goodwill in the light of Explanation 7 to Section 43(1) and 6th proviso to section 32(1)(ii) of the Act were never discussed ... assessee on goodwill post amalgamation should have been at the same value had there been no amalgamation at all, and accordingly depreciation on goodwill arising out of amalgamation should have been NIL in the light of the 6th proviso to section 32(1)(ii) of the Income

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