https://www.taxtmi.com/caselaws?id=800420 Goodwill arising on amalgamation falls within the category of depreciable intangible assets under Section 32(1), including Explanation 3(b), allowing depreciation on such goodwill. The fifth proviso restriction to Section 32(1) cannot be introduced for the first time at the High Court stage where it was neither raised nor adjudicated before the appellate authorities. An unraised restriction does not independently give rise to a substantial question of law from the Tribunal's order, leaving the entitlement to depreciation on goodwill undisturbed. en-us Thu, 01 Oct 2026 00:00:00 +0530 Tue, 06 Oct 2026 08:13:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800420 Goodwill arising on amalgamation falls within the category of depreciable intangible assets under Section 32(1), including Explanation 3(b), allowing depreciation on such goodwill. The fifth proviso restriction to Section 32(1) cannot be introduced for the first time at the High Court stage where it was neither raised nor adjudicated before the appellate authorities. An unraised restriction does not independently give rise to a substantial question of law from the Tribunal's order, leaving the entitlement to depreciation on goodwill undisturbed. Case-Laws Income Tax Thu, 01 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800420