https://www.taxtmi.com/caselaws?id=799998 Excess consideration paid to acquire a software division as a going concern under a slump sale was treated as goodwill attributable to transferred software, licences, business rights and other intangible value, making it eligible for depreciation under section 32(1)(ii). Acquisition of computer systems and intangible business assets without land or buildings did not constitute a transfer of immovable property; consequently, no withholding obligation arose under section 194-IA and no related disallowance under section 40(a)(ia) applied. The excess was recorded as goodwill rather than charged to profit and loss, and its contractual source and commercial basis excluded treatment as unexplained expenditure under section 69C. en-us Fri, 18 Sep 2026 00:00:00 +0530 Wed, 30 Sep 2026 08:41:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799998 Excess consideration paid to acquire a software division as a going concern under a slump sale was treated as goodwill attributable to transferred software, licences, business rights and other intangible value, making it eligible for depreciation under section 32(1)(ii). Acquisition of computer systems and intangible business assets without land or buildings did not constitute a transfer of immovable property; consequently, no withholding obligation arose under section 194-IA and no related disallowance under section 40(a)(ia) applied. The excess was recorded as goodwill rather than charged to profit and loss, and its contractual source and commercial basis excluded treatment as unexplained expenditure under section 69C. Case-Laws Income Tax Fri, 18 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799998