Depreciation of goodwill arising on amalgamation is allowable because such goodwill is an intangible asset and deductible.

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....Depreciation on goodwill arising on amalgamation is treated as allowable because such goodwill constitutes an intangible asset and is eligible for depreciation; earlier decisions relied upon by the taxpayer support this principle and the appellate authority accepted the claim, resulting in allowance of depreciation. The legal point emphasises that goodwill recorded on merger qualifies as depreciable intangible property for tax purposes, and reliance on prior accounting recognition and precedent was determinative of the deductibility outcome.....