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    <title>2026 (8) TMI 204 - ITAT MUMBAI</title>
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    <description>Goodwill arising in a slump sale as the excess of consideration over the net value of acquired assets and liabilities was treated as a newly generated business or commercial right, rather than an asset transferred from the predecessor&#039;s depreciable block. Accordingly, restrictions applicable to transferred depreciable assets did not govern the claim, and goodwill remained eligible for depreciation for assessment year 2018-19 because the later statutory exclusion applied prospectively. Non-compete fees were characterised as revenue expenditure allowable as such, not as a depreciable capital intangible asset; depreciation on those fees was therefore unavailable.</description>
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