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    <description>Goodwill arising from a court-sanctioned amalgamation was treated as a depreciable business asset where the purchase consideration exceeded the net assets taken over under the approved scheme. The sanction by the High Court, after notice to regulatory authorities and without Revenue objection at that stage, supported the bona fides of the arrangement. The Supreme Court view that goodwill forms part of &quot;business or commercial rights of similar nature&quot; under the depreciation provisions was applied, and the allegation of a colourable device was rejected. The later amendment excluding goodwill from depreciable assets was held inapplicable to the assessment year in question, so depreciation on the goodwill was allowed.</description>
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