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“depreciation on goodwill”

DepreciationSection 32Section 32346 judgments

The decision most relied on for depreciation on goodwill is CIT v. Smifs Securities Ltd. (348 ITR 302), cited in 540 judgments on BharatTax.

Leading authorities on depreciation on goodwill

CIT v. Smifs Securities Ltd.
348 ITR 302 · 2012 · Supreme Court
540
citing judgments

Goodwill, whether arising from an amalgamation or a slump sale, is an intangible asset eligible for depreciation under Section 32(1) of the Income-tax Act. While the assessee must prove the existence and valuation of such goodwill, it is recognized as a depreciable asset.

Areva T&D India Ltd. v. DCIT
345 ITR 421 · 2012 · High Court
97
citing judgments

Business contracts and commercial rights of similar nature qualify as intangible assets under Section 32(1)(ii) and are eligible for depreciation. The decision also affirms that goodwill is an intangible asset eligible for depreciation.

Additional/Joint/Deputy/Assistant Commissioner of Incometax/Income-tax Officer v. Mylan Laboratories Ltd.
137 Taxmann.com 178 · 2022 · High Court
60
citing judgments

Goodwill arising on amalgamation is entitled to depreciation. This principle is established by multiple High Court decisions.

Beverages 331 ITR 192 (Del) B.Raveendran Pillai v. CIT
237 Taxmann 230 · 2016 · High Court
59
citing judgments

Goodwill arising on amalgamation is an intangible asset qualifying for depreciation under Section 32 of the Income Tax Act.

Ashwin Vanaspati Industries v. CIT
255 ITR 26 · 2002 · High Court
57
citing judgments

Depreciation is allowable on goodwill acquired through the slump sale of a business. When an assessee claims depreciation on the enhanced cost of an asset supported by a registered valuer's report, tax authorities must produce countervailing evidence, such as a departmental valuation report, to challenge it, rather than simply disregarding the expert opinion.

Kerala Vision Ltd. v. ACIT (
35 Taxmann.com 463 · 2013 · ITAT
52
citing judgments

Transactions carried out on the purchase of off-the-shelf software prior to the jurisdictional High Court's decision in CIT v. Samsung Electronics Co. Ltd. (October 15, 2011) are not liable for Tax Deducted at Source (TDS).

Thiru Arooran Sugar Ltd. v. DCIT
350 ITR 324 · 2013 · High Court
44
citing judgments

A deduction for interest expense on borrowed funds used for interest-free advances to group companies is permissible only if the assessee establishes these advances were from surplus funds. The decision further clarifies eligibility for depreciation on intangible assets like non-compete fees, software, goodwill, and commercial rights under section 32(1)(ii), often arising from a slump sale.

Triune Energy Services (P.) Ltd. v. DCIT
65 Taxmann.com 288 · 2016 · High Court
42
citing judgments

When a business is purchased as a going concern, the consideration paid in excess of the value of its tangible assets is classified as goodwill, which is an intangible asset eligible for depreciation without needing a separate valuation.

Judgments citing depreciation on goodwill

Srf Limited, New Delhi vs. DCIT, Circle- 1, Ltu, New Delhi

In the result, the appeal being ITA No

ITA 4539/DEL/2017[2013-14]Status: DisposedITAT Delhi12 Dec 2025AY 2013-14

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 10ASection 143(3)Section 144C(5)Section 14ASection 92BSection 92C

transfer of CERs and cancellation of CER contracts, short claim of deduction u/s 10A(1A), interest subsidy under TUF scheme, additional depreciation, depreciation on goodwill, deduction of VRS expenditure and of disallowance of ESIC & EPF employee contributions. GROUNDS OF OBJECTIONS IN RESPECT OF TRANSFER PRICING ADJUSTMENTS Corporate Guarantee

Srf Ltd., New Delhi vs. ACIT, New Delhi

In the result, the appeal being ITA No

ITA 80/DEL/2016[2011-12]Status: DisposedITAT Delhi12 Dec 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Sudhir Pareek

For Appellant: Shri Pradeep Dinodia, CAFor Respondent: Shri S.K. Jadhav, CIT DR
Section 10ASection 143(3)Section 144C(5)Section 14ASection 92BSection 92C

transfer of CERs and cancellation of CER contracts, short claim of deduction u/s 10A(1A), interest subsidy under TUF scheme, additional depreciation, depreciation on goodwill, deduction of VRS expenditure and of disallowance of ESIC & EPF employee contributions. GROUNDS OF OBJECTIONS IN RESPECT OF TRANSFER PRICING ADJUSTMENTS Corporate Guarantee

Anmol Himanshu Patel Legal Heir of Late Himanshu Raojibhai Patel, Vadodara vs. The ITO, Ward-1(1)(4) Now Present Jurisdiction the Dy.CIT, Circle-1(1)(1), Vadodara

In the result, the appeal of the assessee stands allowed

ITA 1479/AHD/2025[2015-16]Status: DisposedITAT Ahmedabad09 Dec 2025AY 2015-16

Bench: Shri Sanjay Garg & Shri Narendra Prasad Sinhaआयकर अपील सं /Ita No.1479/Ahd/2025 िनधा"रण वष" /Assessment Year : 2015-16 Anmol Himanshu Patel The Ito बनाम/ (Legal Heir Of Late Himanshu Ward-1(1)(4) V/S. Raojibhai Patel) Now Present Jurisdiction Bs/B-7, Indraprasth Complex The Dy.Cit, Circle-1(1)(1) Nr. Inox Race Course Circle Vadodara – 390 007 Vadodara – 390 007 "थायी लेखा सं./Pan: Acqpp 6460 P (अपीलाथ'/ Appellant) (!( यथ'/ Respondent) Assessee By : Shri Biren Shah, Ar Revenue By : Shri B.P. Srivastava, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 18/09/2025 घोषणा की तारीख /Date Of Pronouncement: 09/12/2025 आदेश/O R D E R Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [Hereinafter Referred To As ‘Cit(A)’] Dated 10/06/2025 Passed U/S.250 Of The Income Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) For The Assessment Year (Ay) 2015-2016. 2. The Assessee, In This Appeal, Has Raised The Following Grounds Of Appeal: Anmol Himanshu Patel (Legal Heir Of Late Himanshu Raojibhai Patel) Vs. Dcit Asst.Year 2015-16. “1. In Law & In The Facts & Circumstances Of The Case Of The Appellant, The Order Passed By The Cit(A) U/S 250 Of The Act Is Bad In Law & Deserves To Be Quashed.

For Appellant: Shri Biren Shah, ARFor Respondent: Shri B.P. Srivastava, Sr.DR
Section 2(22)(e)Section 250

making addition on account of increase in share capital, the Jurisdiction of the AO had ceased at that point. The issue of depreciation on goodwill was altogether different which was to be considered in terms of s. 32 of the Act. If the AO wanted to further examine the issue ... claim of depreciation of Goodwill, in our view, he should have taken the permission to enlarge the scope of limited scrutiny from the Jurisdictional Commissioner as per the law. Merely because the issue of claim of depreciation was germane to the issue of purchase of assets/Goodwill, that itself

M/S Gera Developments Pvt. Ltd, Pune vs. PCIT (Central), Pune

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

ITA 1053/PUN/2024[2020-21]Status: DisposedITAT Pune09 Dec 2025AY 2020-21

Bench: Dr.Manish Borad & Shri Vinay Bhamore

For Appellant: Shri Hari KrishanFor Respondent: Shri Amol Khairnar
Section 143(2)Section 143(3)Section 263

erred in holding that no inquiry, examination or verification has been done in the assessment proceedings regarding the claim of the depreciation on goodwill, without specifying as to which inquiry/examination or verification has not been done by the Assessing Officer. 5. The Ld. Pr. Commissioner of Income Tax has erred ... holding that the assessee is not entitled to the claim of depreciation on goodwill generated on amalgamation. 6. The Ld. Pr. Commissioner of Income Tax has proceeded on the incorrect assumption that the depreciation is not allowable to the assessee in respect of the impaired intangible asset (goodwill), without appreciating

Marvell India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle-4(1)(1), Bengaluru

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

ITA 1608/BANG/2024[2020-21]Status: DisposedITAT Bangalore28 Nov 2025AY 2020-21

Bench: Shri Waseem Ahmed & Shri Rahul Chaudharym/S. Marvell India Private Limited 10Th Floor, Tower D & E Global Technology Park, Marathahalli Outer Ring Road Devarabeesanahalli Village Varthurhobli Bangalore 560 103 ………. Appellant [Pan: Aaecm5559R]

For Appellant: Sri Chavali NarayanFor Respondent: Sri Muthu Shankar
Section 143(3)Section 144C(1)Section 144C(13)Section 200ASection 234ASection 234BSection 234CSection 270ASection 274Section 28

Assessee and in response to the same submission, dated 21/09/2023, was filed by the Assessee wherein it was contended that claim of depreciation of goodwill made by the Assessee was not hit by the amended provisions of Section 32 of the Act since the amendment introduced by the Finance ... that the same was akin to an intangible asset. 5 Assessment Year 2020-2021 Therefore, the Assessee was not eligible to claim depreciation on goodwill. Thus, the Assessing Officer proposed disallowance of depreciation of INR.3,08,21,235/- in respect of goodwill in the Draft Assessment Order. 7.4. The above

Viacom 18, Media Pvt Ltd, Mumbai vs. PCIT-8, Mumbai

ITA 2591/MUM/2025[2019-20]Status: DisposedITAT Mumbai27 Nov 2025AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

For Appellant: Mr. Madhur Agarwal/Ms. MokshaFor Respondent: Mr. Vivek Perampurna, CIT-DR
Section 143(3)Section 144BSection 263Section 32

Assessment Order was passed after verification of relevant details and documentary evidence and application of mind vis-à-vis issues pertaining to depreciation on goodwill and carry forward of losses; 3. failed to appreciate that the NeAC had taken a plausible view supported by judicial precedents and prospective amendment ... Section 32 of the Act and had allowed depreciation on goodwill; Without prejudice to above, the learned PCIT has: Disallowance of Depreciation on Goodwill 4. erred in directing the learned Jurisdictional Assessing Officer ('AO') to verify and disallow the claim of depreciation on goodwill as consistently disallowed by the Department

Sathaiya Ganapathy, Pudukottai vs. ITO, Ward 1, Bardoli

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

ITA 330/SRT/2025[2015-16]Status: DisposedITAT Surat26 Nov 2025AY 2015-16

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.329 & 330/Srt/2025 Assessment Years: (2015-16) (Physical Hearing) Sathaiya Ganapathy, Vs. Ito, Ts No.4114, South 3 Rd Street, Ward – 1, Pukukottai, Tamil Nadu - 622001 Bardoli "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ahbpg2414Q (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Mayank A. Ogriwala, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 26/11/2025

Section 111ASection 16Section 24Section 250Section 271(1)(c)Section 69A

dated 13.10.2023. In the case of Zydus Wellness Ltd. (supra), the assessee had filed return of income but did not claim depreciation on goodwill. It had claimed depreciation during the assessment proceedings, which was rejected because assessee did not make the claim in the original return nor did it file

Sathaiya Ganapathy, Pudukottai vs. ITO, Ward 1, Bardoli

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

ITA 329/SRT/2025[2015-16]Status: DisposedITAT Surat26 Nov 2025AY 2015-16

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.329 & 330/Srt/2025 Assessment Years: (2015-16) (Physical Hearing) Sathaiya Ganapathy, Vs. Ito, Ts No.4114, South 3 Rd Street, Ward – 1, Pukukottai, Tamil Nadu - 622001 Bardoli "थायीलेखासं./जीआइआरसं./Pan/Gir No: Ahbpg2414Q (अपीलाथ"/Appellant) (""थ" /Respondent) Appellant By Shri Mayank A. Ogriwala, Ca Respondent By Shri Ajay Uke, Sr. Dr Date Of Hearing 02/09/2025 Date Of Pronouncement 26/11/2025

Section 111ASection 16Section 24Section 250Section 271(1)(c)Section 69A

dated 13.10.2023. In the case of Zydus Wellness Ltd. (supra), the assessee had filed return of income but did not claim depreciation on goodwill. It had claimed depreciation during the assessment proceedings, which was rejected because assessee did not make the claim in the original return nor did it file

Gbt India Private Limited, New Delhi vs. ACIT, OSD, Delhi

In the result, the assessee’s appeal is allowed as above

ITA 1764/DEL/2022[2018-19]Status: DisposedITAT Delhi26 Nov 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 143(3)Section 234ASection 36(1)(vii)Section 36(2)

DRP/Ld. AO erred in not following the principle of consistency by failing to appreciate that the adjustment qua depreciation on goodwill and disallowance of bad debts, are covered in favour the Appellant by the decision of this Hon'ble Tribunal in Appellant's own case for previous ... includes payment for Goodwill also. Among various business expenditure, the appellant assessee also claimed deductions of (i) INR 46,152,224 as depreciation on goodwill and (ii) INR 15,912,680 on account of bad debts written off. 3.2 Following international transactions of the appellant assessee with its Associate Enterprises

Assistant Commissioner of Income Tax, Mumbai vs. Siyaram Silk Mills Limited, Mumbai

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

ITA 2941/MUM/2025[2016-17]Status: DisposedITAT Mumbai25 Nov 2025AY 2016-17

Bench: Hon’Ble Shri Sandeep Gosain & Hon’Ble Shri Girish Agrawalassistant Commissioner Of Vs. Siyaram Silk Mills Income Tax Limited Room No. 506, 5Th Floor, B5, Trade World, Aaykar Bhavan, M K Road, Kamala City, Senapati Churchgate, Bapat Margf, Lower Mumbai- 400020 Parel West, Mumbai- 400013 Pan/Gir No. Aaacs6995D (Applicant) (Respondent)

Section 250Section 32Section 32(1)

assessment year 2016-17. The revenue has raised the following grounds of appeal: Grounds of Appeal 2 Siyaram Silk Mills Limited 1. Depreciation on Goodwill (Rs. 4,01,99,836/-] 1.1 On the facts and in the circumstances of the case and in law, whether the Ld.CIT(A) erred ... finding in para 7.3 of its order, the same is reproduced herein below:- 7.3.1 The issue involved in this ground is whether depreciation on goodwill upon amalgamation is allowable or not. The facts of the case are that as per scheme of amalgamation approved by Bombay High Court, M/s Balakrishna

Signode India Limited, Hyderabad vs. ACIT, Circle-3(1), Hyderabad

ITA 240/HYD/2023[2015-16]Status: DisposedITAT Hyderabad14 Nov 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri H. SrinivasuluFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(3)Section 144C(5)Section 32

company at Rs.143,99,26,151/- by making additions on account of TP adjustments proposed by the TPO and by making disallowance of depreciation on ‘Goodwill’ amounting to Rs.130,06,83,295/- as against the returned income of the assessee company at Rs.13,86,90,068/- vide Draft Assessment Order ... assessee company in respect of non-acceptance 12 ITA.No.434/Hyd/2021 & ITA 240/Hyd/2023 M/s. Signode India Limited of valuation of Goodwill and disallowance of depreciation on goodwill by the Assessing Officer is found to be in order and with respect to TP adjustment addition made by the Assessing Officer

Signode India Limited, Hyderabad vs. Deputy Commissioner of Income Tax, Circle-3(1), Hyderabad

ITA 434/HYD/2021[2016-17]Status: DisposedITAT Hyderabad14 Nov 2025AY 2016-17

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: Shri H. SrinivasuluFor Respondent: Dr. Narendra Kumar Naik, CIT-DR
Section 143(3)Section 144C(5)Section 32

company at Rs.143,99,26,151/- by making additions on account of TP adjustments proposed by the TPO and by making disallowance of depreciation on ‘Goodwill’ amounting to Rs.130,06,83,295/- as against the returned income of the assessee company at Rs.13,86,90,068/- vide Draft Assessment Order ... assessee company in respect of non-acceptance 12 ITA.No.434/Hyd/2021 & ITA 240/Hyd/2023 M/s. Signode India Limited of valuation of Goodwill and disallowance of depreciation on goodwill by the Assessing Officer is found to be in order and with respect to TP adjustment addition made by the Assessing Officer

Sh. Suresh Pal, Yamuna Nagar vs. ITO, Ward 5, Yamuna Nagar

ITA 668/CHANDI/2022[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

आयकर अपीलीय अधिकरण, चण्डीगढ़ न्यायपीठ “ए”, चण्डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, CHANDIGARH HEARING THROUGH: PHYSICAL

M/S. Barbeque Nation Hospitality Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

ITA 26/BANG/2024[2018-19]Status: DisposedITAT Bangalore31 Oct 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore
Section 153ASection 234ASection 250

unabated/ completed assessment year on the facts and circumstances of the case. 5. The authorities below failed to appreciate that the disallowance of depreciation on goodwill is discernible from the financial statements which were already available with the income tax department during the course of the original assessment proceedings ... unabated/ completed assessment year on the facts and circumstances of the case. 5. The authorities below failed to appreciate that the disallowance of depreciation on goodwill is discernible from the financial statements which were already available with the income tax department during the course of the original assessment proceedings

M/S. Barbeque Nation Hospitality Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

ITA 25/BANG/2024[2017-18]Status: DisposedITAT Bangalore31 Oct 2025AY 2017-18

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Respondent: Shri. A. Shankar, Sr. Advocate
Section 132Section 153ASection 234ASection 250

unabated/ completed assessment year on the facts and circumstances of the case. 5. The authorities below failed to appreciate that the disallowance of depreciation on goodwill is discernible from the financial statements which were already available with the income tax department during the course of the original assessment proceedings ... unabated/ completed assessment year on the facts and circumstances of the case. 5. The authorities below failed to appreciate that the disallowance of depreciation on goodwill is discernible from the financial statements which were already available with the income tax department during the course of the original assessment proceedings

M/S. Barbeque Nation Hospitality Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Central Circle-2(2), Bengaluru

In the result, appeals filed by the assessee are partly allowed

ITA 24/BANG/2024[2016-17]Status: DisposedITAT Bangalore31 Oct 2025AY 2016-17

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore
Section 153ASection 234ASection 250

unabated/ completed assessment year on the facts and circumstances of the case. 5. The authorities below failed to appreciate that the disallowance of depreciation on goodwill is discernible from the financial statements which were already available with the income tax department during the course of the original assessment proceedings ... unabated/ completed assessment year on the facts and circumstances of the case. 5. The authorities below failed to appreciate that the disallowance of depreciation on goodwill is discernible from the financial statements which were already available with the income tax department during the course of the original assessment ITA Nos.21

M/S. Barbeque Nation Hospitality Ltd, Bengaluru vs. Deputy Commissioner of Income-Tax Officer, Central Circle-2(2), Bengaluru

ITA 23/BANG/2024[2015-16]Status: DisposedITAT Bangalore31 Oct 2025AY 2015-16

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

Section 153ASection 234ASection 250

unabated/ completed assessment year on the facts and circumstances of the case. 5. The authorities below failed to appreciate that the disallowance of depreciation on goodwill is discernible from the financial statements which were already available with the income tax department during the course of the original assessment proceedings ... unabated/ completed assessment year on the facts and circumstances of the case. 5. The authorities below failed to appreciate that the disallowance of depreciation on goodwill is discernible from the financial statements which were already available with the income tax department during the course of the original assessment proceedings

M/S. Barbeque Nation Hospitality Ltd, Bengaluru vs. Deputy Commissioner of Income-Tax, Central Circle-2(2), Bengaluru

In the result, appeals filed by the assessee are partly allowed

ITA 22/BANG/2024[2014-15]Status: DisposedITAT Bangalore31 Oct 2025AY 2014-15

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore
Section 153ASection 234ASection 250

unabated/ completed assessment year on the facts and circumstances of the case. 5. The authorities below failed to appreciate that the disallowance of depreciation on goodwill is discernible from the financial statements which were already available with the income tax department during the course of the original assessment proceedings ... unabated/ completed assessment year on the facts and circumstances of the case. 5. The authorities below failed to appreciate that the disallowance of depreciation on goodwill is discernible from the financial statements which were already available with the income tax department during the course of the original assessment ITA Nos.21

M/S. Barbeque Nation Hospitality Ltd, Bengaluru vs. Deputy Commissioner of Income-Tax, Circle-2(2), Bengaluru

In the result, appeals filed by the assessee are partly allowed

ITA 21/BANG/2024[2013-14]Status: DisposedITAT Bangalore31 Oct 2025AY 2013-14

Bench: Shri. Laxmi Prasad Sahu & Shri. Keshav Dubey

For Appellant: Shri. A. Shankar, Sr. AdvocateFor Respondent: Shri. K. M. Mahesh, CIT(DR)(ITAT), Bangalore
Section 153ASection 234ASection 250

unabated/ completed assessment year on the facts and circumstances of the case. 5. The authorities below failed to appreciate that the disallowance of depreciation on goodwill is discernible from the financial statements which were already available with the income tax department during the course of the original assessment proceedings ... unabated/ completed assessment year on the facts and circumstances of the case. 5. The authorities below failed to appreciate that the disallowance of depreciation on goodwill is discernible from the financial statements which were already available with the income tax department during the course of the original assessment ITA Nos.21

DCIT CC 8(2), Mumbai vs. Echjay Industries Private Limited, Mumbai

In the result, both the appeals of the Revenue are dismissed

ITA 5437/MUM/2025[2020-21]Status: DisposedITAT Mumbai30 Oct 2025AY 2020-21

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

For Respondent: Mr. N.R. Rao, Adv
Section 32Section 32(1)

claim themselves had not claimed or were not eligible to claim themselves had not claimed or were not eligible to claim any depreciation on goodwill and therefore, the WDV was any depreciation on goodwill and therefore, the WDV was any depreciation on goodwill and therefore ... declared by various judicial fora, held al facts and the law declared by various judicial fora, held that the assessee was entitled to depreciation on goodwill arising that the assessee was entitled to depreciation on goodwill arising that the assessee was entitled to depreciation on goodwill arising out of amalgamation