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depreciation. In the present case, the ITA No.281 and 222/Ahd/2021 37 goodwill represents the expected future economic benefits arising from business consolidation, synergy, and operational continuity — all recognized aspects of goodwill under law. Revised Ground No. 7: 65. The Department seeks to apply Explanation 7 to section 43(1), sixth proviso to section 32(1), section