Goodwill arising from the slump-sale acquisition of a going...

Goodwill arising from the slump-sale acquisition of a going software business division qualifies as a depreciable intangible asset where the Business Transfer Agreement transfers the division's products, employees, licences, permits and assets. Consideration exceeding the net value of transferred assets and liabilities may represent goodwill and other intangible assets rather than unexplained expenditure, where it is recorded under the transfer agreement and not claimed as revenue expenditure. Tax deduction at source on transfer of immovable property does not apply where the transferred business assets comprise computer systems and intangible assets, with no land, building or part of a building transferred. Depreciation and deletion of the related disallowance and addition were sustained.