https://www.taxtmi.com/caselaws?id=460984 ITAT Delhi dismissed the assessee's appeal regarding depreciation on goodwill created post-demerger. The tribunal held that depreciation on goodwill arising from demerger schemes must be apportioned based on days of asset usage. Under Section 32(1) proviso, the demerged company cannot claim depreciation on newly created assets exceeding what was allowable to the original entity. The court emphasized that amalgamation and demerger are revenue-neutral transactions designed for business purposes, and gains from such capital asset transfers to Indian companies remain exempt. en-us Fri, 03 Feb 2023 00:00:00 +0530 Wed, 05 Mar 2025 18:57:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460984 ITAT Delhi dismissed the assessee's appeal regarding depreciation on goodwill created post-demerger. The tribunal held that depreciation on goodwill arising from demerger schemes must be apportioned based on days of asset usage. Under Section 32(1) proviso, the demerged company cannot claim depreciation on newly created assets exceeding what was allowable to the original entity. The court emphasized that amalgamation and demerger are revenue-neutral transactions designed for business purposes, and gains from such capital asset transfers to Indian companies remain exempt. Case-Laws Income Tax Fri, 03 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460984