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    <title>2023 (11) TMI 119 - ITAT DELHI</title>
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    <description>Depreciation on non-compete fee was treated as unavailable where the payment did not qualify as an eligible intangible asset under section 32(1)(ii), and the claim was disallowed. Set-off of brought forward losses after amalgamation was also denied because the statutory conditions under section 72A were not satisfied, so the benefit could not be claimed for the year under review. The note records that both additions were sustained and the assessee&#039;s appeal failed in full.</description>
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      <description>Depreciation on non-compete fee was treated as unavailable where the payment did not qualify as an eligible intangible asset under section 32(1)(ii), and the claim was disallowed. Set-off of brought forward losses after amalgamation was also denied because the statutory conditions under section 72A were not satisfied, so the benefit could not be claimed for the year under review. The note records that both additions were sustained and the assessee&#039;s appeal failed in full.</description>
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