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The ITAT overturned the AO's disallowance of depreciation on goodwill arising from amalgamation, holding that the goodwill recognized pursuant to the approved scheme of amalgamation and valuation report is valid for depreciation claims. The AO erred by valuing intangible assets at NIL cost despite the consideration exceeding net assets acquired. Following the Supreme Court precedent, the differential amount paid over net assets constitutes goodwill, which is eligible for depreciation. Consequently, the appellate tribunal allowed the assessee's appeal, permitting depreciation on goodwill recognized on amalgamation.
The ITAT overturned the AO's disallowance of depreciation on goodwill arising from amalgamation, holding that the goodwill recognized pursuant to the approved scheme of amalgamation and valuation report is valid for depreciation claims. The AO erred by valuing intangible assets at NIL cost despite the consideration exceeding net assets acquired. Following the Supreme Court precedent, the differential amount paid over net assets constitutes goodwill, which is eligible for depreciation. Consequently, the appellate tribunal allowed the assessee's appeal, permitting depreciation on goodwill recognized on amalgamation.
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