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    <title>2026 (4) TMI 182 - ITAT AHMEDABAD</title>
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    <description>Goodwill arising from amalgamation was treated as an acquired intangible asset representing a business or commercial right, so depreciation under section 32(1) was allowable. Section 14A disallowance could not be made by applying Rule 8D because the Assessing Officer had not first recorded dissatisfaction with the assessee&#039;s suo motu computation, making the adjustment unsustainable. Reassessment was barred by limitation because the fresh section 148 notice was issued beyond the surviving statutory period. The assessment framed in the name of a company that had ceased to exist after conversion into an LLP was void, as an assessment on a non-existing entity is without jurisdiction.</description>
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