PCIT's Challenge on Goodwill Depreciation u/s 263 Overruled; 5th Proviso to Section 32(1) Found Inapplicable.

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....Revision u/s 263 - depreciation claimed on goodwill arose out of amalgamation - PCIT has assumed jurisdiction u/s. 263 of the Act on the sole basis of application of 5th proviso to section 32(1) of the Act, towards depreciation on goodwill. In view of the factual matrix as stated in preceding paragraphs and non-applicability of 5th proviso to section 32(1) of the Income Tax Act, 1961, there cannot be error in relation to the view taken by the Assessing Officer while framing the original assessment. - AT....