PCIT's revision u/s 263 on depreciation of goodwill from amalgamation ruled incorrect; Section 32(1) proviso inapplicable.

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....Revision u/s 263 by CIT - depreciation on goodwill - the assessee has rightly claimed depreciation on goodwill arise out of amalgamation, because, 5th proviso to sec.32(1) has no application to the facts of the present case. Therefore, we are of the considered view that assumption of jurisdiction by the PCIT on this issue is fails. - AT....