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    <title>2026 (5) TMI 42 - ITAT KOLKATA</title>
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    <description>Goodwill arising from a court-approved amalgamation was treated as an intangible asset eligible for depreciation, and the 5th proviso to section 32(1) and Explanation 3 to section 43(1) were held inapplicable on the facts. Where no exempt income was earned during the year, disallowance under section 14A read with rule 8D was deleted because the statutory nexus to exempt income was absent. An additional ground challenging disturbance of the opening written-down value was admitted as a pure question of law and was allowed, supporting the depreciation claim. The assessee obtained relief on the disputed depreciation and related cross-objection issues.</description>
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