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of Disallowance of the claim of depreciation on intangible asset - amalgamation scheme initiated - when there is no transfer of the asset as well as there is no valuation of the asset, there cannot be any claim of ownership or claim of depreciation. With regard to non-compete agreement, there is no such agreement on record and even if it exists, the amount paid for non-compete agreement is capital payment and not eligible for depreciation. - AT
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