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“goodwill arising on amalgamation”

Mergers & RestructuringSection 32Section 3273 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

appointed date of 01.04.2014. It was submitted that in both amalgamations the excess of consideration paid over the net assets acquired represents goodwill arising on amalgamation. However, the assessee followed the pooling of interest method and adjusted the excess amount against its General Reserve account instead of recognising the same ... Tribunal allowed the claim of depreciation on goodwill. Accordingly, the Ld. AR submitted that the claim of the assessee for depreciation on goodwill arising on amalgamation may be allowed. 9. The Learned Departmental Representative (“Ld. DR”), on the other hand, supported the order

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

goodwill, where the consideration paid exceeds the net book value of the assets acquired and is duly supported by a professional valuation. Further, goodwill arising from amalgamation between group entities, where there may be common control or overlapping ownership, is specifically contemplated under section ... DCIT, ITA Nos. 198 & 199/Ahd/2023 for A.Ys. 2016–17 and 2017–18, wherein the Tribunal allowed the claim of depreciation on goodwill arising on amalgamation of ACIT Vs. Intas Pharmaceuticals Ltd Asst. Year : 2016-17 - 15– wholly-owned subsidiaries. In that case, the goodwill had been recorded in the books

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)

sanctioned by both the Hon'ble Bombay and Calcutta High Courts. The excess consideration paid over the net assets acquired was treated as goodwill arising on amalgamation and depreciation was claimed by the assessee. The AO denied the depreciation holding that goodwill is not an asset by referring to explanation

ASSISSTANT COMMISSIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

ITA 1763/CHNY/2024[2017-18]Status: DisposedITAT Chennai21 Jan 2026AY 2017-18
Section 143(3)Section 43(1)

nITA No.: 1731/CHNY/2024 AY 2014-15\n5. The first ground of appeal is regarding the issue of allowability of\ndepreciation on goodwill arising on amalgamation of FLSmidth Pfister India\nLimited with FLSmidth Private Limited during AY 2014-15. The brief facts are\nthat FLSmidth Pfister India Limited (FPIL ... nature of goodwill eligible for tax depreciation in the hands of\nthe Assessee. Consequently, the assessee claimed tax depreciation at 25%\non goodwill, arising on amalgamation of FPIL with the assessee. The AO\ndisallowed the assessee's claim of depreciation on goodwill arising on\namalgamation. The CIT(A) allowed

ASSISSTANT COMMISSIONER OF INCOME CORPORATE CIRCLE 1-1, CHENNAI vs. FL SMIDTH PRIVATE LIMITED, KANCHIPURAM

ITA 1731/CHNY/2024[2014-15]Status: DisposedITAT Chennai21 Jan 2026AY 2014-15
Section 143(3)Section 43(1)

nITA No.: 1731/CHNY/2024 AY 2014-15\n5. The first ground of appeal is regarding the issue of allowability of\ndepreciation on goodwill arising on amalgamation of FLSmidth Pfister India\nLimited with FLSmidth Private Limited during AY 2014-15. The brief facts are\nthat FLSmidth Pfister India Limited (FPIL ... nature of goodwill eligible for tax depreciation in the hands of\nthe Assessee. Consequently, the assessee claimed tax depreciation at 25%\non goodwill, arising on amalgamation of FPIL with the assessee. The AO\ndisallowed the assessee's claim of depreciation on goodwill arising on\namalgamation. The CIT(A) allowed

ASSISSTANT COMMISIONER OF INCOME TAX CORPORATE CIRCLE 1 1, CHENNAI vs. FL SMITH PRIVATE LIMITED, KANCHIPURAM

In the result, the appeals of the revenue in ITA

ITA 1682/CHNY/2024[2015-16]Status: DisposedITAT Chennai21 Jan 2026AY 2015-16
Section 143(3)Section 43(1)

nITA No.: 1731/CHNY/2024 AY 2014-15\n5. The first ground of appeal is regarding the issue of allowability of\ndepreciation on goodwill arising on amalgamation of FLSmidth Pfister India\nLimited with FLSmidth Private Limited during AY 2014-15. The brief facts are\nthat FLSmidth Pfister India Limited (FPIL ... nature of goodwill eligible for tax depreciation in the hands of\nthe Assessee. Consequently, the assessee claimed tax depreciation at 25%\non goodwill, arising on amalgamation of FPIL with the assessee. The AO\ndisallowed the assessee's claim of depreciation on goodwill arising on\namalgamation. The CIT(A) allowed

ACIT- 6(1)(2), MUMBAI, MUMBAI vs. SIYARAM SILK MILLS LIMITED, MUMBAI

In the result, the appeal of the revenue bearing ITA No

ITA 5692/MUM/2025[2017-18]Status: DisposedITAT Mumbai07 Jan 2026AY 2017-18

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

Section 143(3)Section 250Section 32

ordinate Bench of the ITAT, Mumbai, in the assessee’s own case for A.Y. 2016-17 (supra), wherein depreciation on goodwill arising on amalgamation, accounted for in an earlier year, was held to be allowable. Respectfully following the judicial precedent and the directions of the co-ordinate Bench

VIACOM 18, MEDIA PVT LTD ,MUMBAI vs. PCIT-8, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 2591/MUM/2025[2019-20]Status: DisposedITAT Mumbai27 Nov 2025AY 2019-20
Section 143(3)Section 144BSection 263Section 32

depreciable asset u/s 32(1) of the Act and therefore,\nAccording to the assessee sixth proviso was not intended to deny\ndepreciation on goodwill arising on amalgamation.\n\n8.7 The learned counsel for the assessee has placed reliance on\nthe decision of the Mumbai Tribunal in Dow Chemical International ... DCIT [2024] 169 taxmann.com 290 (Mum.), wherein\ndepreciation on goodwill arising upon amalgamation was held\nallowable notwithstanding the sixth proviso, on the very ground\nthat the amalgamating entity did not possess or claim depreciation\non such goodwill. The ITAT allowed depreciation on Goodwill in the\nbooks of amalgamated company

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)

amalgamation sanctioned by both the Bombay and Calcutta High Court. The excess consideration paid over the net assets acquired was treated as goodwill arising on amalgamation and depreciation was claimed by the assessee. The AO denied the depreciation holding that goodwill is not an asset by referring to explanation ... sanctioned by both the Hon’ble Bombay and Calcutta High Courts. The excess consideration paid over the net assets acquired was treated as goodwill arising on amalgamation and depreciation was claimed by the assessee. The AO denied the depreciation holding that goodwill is not an asset by referring to explanation

BAKERI PROJECTS PRIVATE LIMITED,AHMEDABAD vs. THE DY.CIT, CIRCLE-1(1)(1), AHMEDABAD

In the result, the appeals of the assessee on this ground are allowed

ITA 785/AHD/2023[2016-17]Status: DisposedITAT Ahmedabad10 Oct 2025AY 2016-17

Bench: Dr. Brr Kumar & Ms. Suchitra Kambleassessment Year 2016-17

For Appellant: Shri S.N. Soparkar, A.RFor Respondent: Shri R.P. Rastogi, CIT-D.R
Section 143(2)Section 271(1)(c)Section 274Section 32Section 32(1)Section 32(1)(ii)Section 43(1)Section 43(6)

assessee can claim depreciation. In the case of Zydus Wellness Centre Ltd. Vs. DCIT, the ITAT allowed the claim of depreciation on goodwill arising on amalgamation claimed by the assessee during the course of assessment proceedings by filing revised computation of income and without filing revised return of income

THE ACTI , CIRCLE-3(1)(1),, AHMEDABAD vs. NIRMA LIMITED,, AHMEDABAD

ITA 1437/AHD/2019[2016-17]Status: DisposedITAT Ahmedabad28 Aug 2025AY 2016-17
For Appellant: \nShri Bandish Soparkar, withFor Respondent: \nShri Alpesh Parmar, CIT-DR
Section 115JSection 143(3)Section 14A

Nos.2007\n& 2008/Ahd/2017 and ITA No. 516/Ahd/2018, order dated\n30.06.2025). We find that the issue relating to allowability of\ndepreciation on goodwill arising on amalgamation of Saurashtra\nChemicals Ltd. with the assessee stood adjudicated by the Co-\nordinate Bench in favour of the assessee.\n51. The Co-ordinate Bench ... assessee can claim depreciation. In the\ncase of Zydus Wellness Centre Ltd. Vs. DCIT, the ITAT allowed the\nclaim of depreciation on goodwill arising on amalgamation claimed by\nthe assessee during the course of assessment proceedings by filing\nrevised computation of income and without filing revised return of\nincome

THE ACTI , CIRCLE-3(1)(1),, AHMEDABAD vs. NIRMA LIMITED,, AHMEDABAD

ITA 1436/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad28 Aug 2025AY 2015-16
For Appellant: \nShri Bandish Soparkar, withFor Respondent: \nShri Alpesh Parmar, CIT-DR
Section 115JSection 143(3)Section 14A

Nos.2007\n& 2008/Ahd/2017 and ITA No. 516/Ahd/2018, order dated\n30.06.2025). We find that the issue relating to allowability of\ndepreciation on goodwill arising on amalgamation of Saurashtra\nChemicals Ltd. with the assessee stood adjudicated by the Co-\nordinate Bench in favour of the assessee.\n51. The Co-ordinate Bench ... assessee can claim depreciation. In the\ncase of Zydus Wellness Centre Ltd. Vs. DCIT, the ITAT allowed the\nclaim of depreciation on goodwill arising on amalgamation claimed by\nthe assessee during the course of assessment proceedings by filing\nrevised computation of income and without filing revised return of\n30\nITA

NIRMA LIMITED,,AHMEDABAD vs. THE DCTI , CIRCLE-3(1)(1),, AHMEDABAD

ITA 1413/AHD/2019[2016-17]Status: DisposedITAT Ahmedabad28 Aug 2025AY 2016-17
For Appellant: \nShri Bandish Soparkar, withFor Respondent: \nShri Alpesh Parmar, CIT-DR
Section 115JSection 143(3)Section 14A

Nos.2007\n& 2008/Ahd/2017 and ITA No. 516/Ahd/2018, order dated\n30.06.2025). We find that the issue relating to allowability of\ndepreciation on goodwill arising on amalgamation of Saurashtra\nChemicals Ltd. with the assessee stood adjudicated by the Co-\nordinate Bench in favour of the assessee.\n51. The Co-ordinate Bench ... assessee can claim depreciation. In the\ncase of Zydus Wellness Centre Ltd. Vs. DCIT, the ITAT allowed the\nclaim of depreciation on goodwill arising on amalgamation claimed by\nthe assessee during the course of assessment proceedings by filing\nrevised computation of income and without filing revised return of\nITA Nos.1412-1413/Ahd/2019

NIRMA LIMITED,,AHMEDABAD vs. THE DCTI , CIRCLE-3(1)(1),, AHMEDABAD

ITA 1412/AHD/2019[2015-16]Status: DisposedITAT Ahmedabad28 Aug 2025AY 2015-16
For Appellant: \nShri Bandish Soparkar, withFor Respondent: \nShri Alpesh Parmar, CIT-DR
Section 115JSection 143(3)Section 14A

Nos.2007\n& 2008/Ahd/2017 and ITA No. 516/Ahd/2018, order dated\n30.06.2025). We find that the issue relating to allowability of\ndepreciation on goodwill arising on amalgamation of Saurashtra\nChemicals Ltd. with the assessee stood adjudicated by the Co-\nordinate Bench in favour of the assessee.\n51. The Co-ordinate Bench ... assessee can claim depreciation. In the\ncase of Zydus Wellness Centre Ltd. Vs. DCIT, the ITAT allowed the\nclaim of depreciation on goodwill arising on amalgamation claimed by\nthe assessee during the course of assessment proceedings by filing\nrevised computation of income and without filing revised return of\nincome

ACIT, CIRCLE-1(1), RAJKOT, RAJKOT vs. GANDHI REALITY (INDIA) PRIVATE LIMITED, RAJKOT

In the result, the appeal of the Revenue is dismissed

ITA 110/RJT/2025[2018-19]Status: DisposedITAT Rajkot25 Aug 2025AY 2018-19

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm

For Appellant: Shri R. K. Doshi, Ld. ARFor Respondent: Shri Praveen Verma, Ld. CIT. (DR)
Section 142(1)Section 143(2)Section 143(3)Section 144BSection 230

assets in the nature of know-how, patents, copyrights, trademarks, licenses, franchises 'or any other business or commercial rights of similar nature. The Goodwill arising on amalgamation, being in the nature of any other commercial or business right, falls under the category of an intangible asset and hence, eligible

ADITYA BIRLA FINANCE LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME-TAX - 2(1)(1), MUMBAI

In the result, the appeal is partly allowed

ITA 4821/MUM/2024[AY 2017-18]Status: DisposedITAT Mumbai08 Jul 2025
For Appellant: Shri Yogesh Thar & Ms. S.Jayaram, ARsFor Respondent: Shri Rajesh Kumar Yadav, (CIT DR)
Section 143(3)Section 32Section 43BSection 80G

well settled by the decision of Hon'ble Supreme Court in the\ncase of CIT v. Smifs Securities Ltd [348 ITR 302];\n2.2.2 goodwill arising on amalgamation is an intangible asset on which\ndepreciation w/s.32 of the Act is allowable; and\n2.2.3 is not merely a fictitious asset;\n2.3 ... alia held as\nunder:\n\"6. In respect of Ground no.1 (with its sub-ground nos.1.1 to 1.4) relating to\ndeprecation claim on Goodwill arising on amalgamation, the Ld. AR argued that the\nLd. AO has erred in observing that the assessee has incurred no actual cost for\nacquisition

JT. CTI (OSD), CIRCLE-3(1)(1),, AHMEDABAD vs. M/S. NIRMA LIMITED,, AHMEDABAD

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 791/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 2(24)(x)Section 234BSection 271

which comes to Rs. 23,03,33,782/- may be allowed to the assessee on completion of assessment. 10.2 The depreciation on goodwill arising on amalgamation claimed by the assessee company is not allowable for the reasons discussed in subsequent paragraphs. Even before going into the question of allowability ... assessee over the value of net assets acquired of YSN Shares and Securities Private Limited (Amalgamating Company) should be considered as goodwill arising on amalgamation. It was claimed that the extra consideration was paid towards the reputation which the Amalgamating Company was enjoying in order to retain its existing clientele

NIRMA LIMITED,,AHMEDABAD vs. DCIT, CIRCLE-3(1)(1),, AHMEDABAD

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 516/AHD/2018[2014-15]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2014-15

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 2(24)(x)Section 234BSection 271

which comes to Rs. 23,03,33,782/- may be allowed to the assessee on completion of assessment. 10.2 The depreciation on goodwill arising on amalgamation claimed by the assessee company is not allowable for the reasons discussed in subsequent paragraphs. Even before going into the question of allowability ... assessee over the value of net assets acquired of YSN Shares and Securities Private Limited (Amalgamating Company) should be considered as goodwill arising on amalgamation. It was claimed that the extra consideration was paid towards the reputation which the Amalgamating Company was enjoying in order to retain its existing clientele

THE DCIT, CIR-3(1)(1), AHMEDABAD vs. M/S. NIRMA LIMITED,, AHMEDABAD

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 2224/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 2(24)(x)Section 234BSection 271

which comes to Rs. 23,03,33,782/- may be allowed to the assessee on completion of assessment. 10.2 The depreciation on goodwill arising on amalgamation claimed by the assessee company is not allowable for the reasons discussed in subsequent paragraphs. Even before going into the question of allowability ... assessee over the value of net assets acquired of YSN Shares and Securities Private Limited (Amalgamating Company) should be considered as goodwill arising on amalgamation. It was claimed that the extra consideration was paid towards the reputation which the Amalgamating Company was enjoying in order to retain its existing clientele

M/S. NIRMA LIMITED,,AHMEDABAD vs. THE DCIT, CIRCLE-3(1)(1),, AHMEDABAD

In the result, all the appeals filed by the Revenue and the appeals for AYs 2012-

ITA 2008/AHD/2017[2013-14]Status: DisposedITAT Ahmedabad30 Jun 2025AY 2013-14

Bench: Dr. B.R.R. Kumar, Vice- & Ms. Suchitra R. Kamble

For Appellant: Shri S.N. Soparkar, Sr.AdvocateFor Respondent: Shri Alpesh Parmar, CIT-DR
Section 143(3)Section 2(24)(x)Section 234BSection 271

which comes to Rs. 23,03,33,782/- may be allowed to the assessee on completion of assessment. 10.2 The depreciation on goodwill arising on amalgamation claimed by the assessee company is not allowable for the reasons discussed in subsequent paragraphs. Even before going into the question of allowability ... assessee over the value of net assets acquired of YSN Shares and Securities Private Limited (Amalgamating Company) should be considered as goodwill arising on amalgamation. It was claimed that the extra consideration was paid towards the reputation which the Amalgamating Company was enjoying in order to retain its existing clientele

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