#business transfer agreement

ITAT Bangalore has ruled that goodwill acquired in a slump sale qualifies for depreciation under Section 32, even if it arises from excess consideration over net assets, rejecting the revenue's argument that it is a self-generated asset. This clarifies that business acquisitions via slump sale are distinct from amalgamations and affirms the tax treatment of intangible assets in corporate restructuring, impacting M&A valuations and audit practices nationwide.

ITAT Delhi deleted a Rs. 10.15 crore deemed interest addition on interest-free advances acquired through a slump sale, holding that the Revenue’s long-standing acceptance of such advances in prior years precludes retrospective disallowance. This reinforces commercial expediency and consistency as binding limits on tax authorities, protecting businesses that structure group financing through asset acquisitions.