https://www.taxtmi.com/caselaws?id=792574 Appellate powers under section 254 permit admission of a pure legal ground where the relevant facts are already on record. Goodwill arising on amalgamation is a depreciable intangible asset, and the proviso to section 32(1) does not mechanically bar depreciation on goodwill created for the first time. A non-compete covenant also qualifies as a business or commercial right eligible for depreciation. Interest disallowance under section 36(1)(iii) fails where sufficient interest-free funds exist and no nexus with borrowed funds is shown, while estimated disallowances of expenses cannot stand without specific adverse findings. The article also notes that appellate authorities may entertain a debenture premium claim, and that connectivity and network acquisition issues required limited factual verification. en-us Tue, 26 May 2026 00:00:00 +0530 Sat, 30 May 2026 08:29:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792574 Appellate powers under section 254 permit admission of a pure legal ground where the relevant facts are already on record. Goodwill arising on amalgamation is a depreciable intangible asset, and the proviso to section 32(1) does not mechanically bar depreciation on goodwill created for the first time. A non-compete covenant also qualifies as a business or commercial right eligible for depreciation. Interest disallowance under section 36(1)(iii) fails where sufficient interest-free funds exist and no nexus with borrowed funds is shown, while estimated disallowances of expenses cannot stand without specific adverse findings. The article also notes that appellate authorities may entertain a debenture premium claim, and that connectivity and network acquisition issues required limited factual verification. Case-Laws Income Tax Tue, 26 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792574