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    <title>2026 (5) TMI 1619 - ITAT AHMEDABAD</title>
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    <description>Goodwill arising from amalgamation was treated as an intangible asset eligible for depreciation under section 32(1)(ii) of the Income-tax Act, following the principle that goodwill falls within &quot;business or commercial rights of similar nature&quot; recognised in Smifs Securities. The Finance Act, 2021 restrictions excluding goodwill from depreciation-related treatment were held to operate prospectively from assessment year 2021-22 and did not apply to the years under discussion. Objections based on separate payment, valuation, and other factual distinctions did not displace the finding that the goodwill was acquired under the amalgamation scheme and remained depreciable under the pre-amendment law.</description>
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