#Depreciation on Goodwill

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 Ahmedabad reaffirms that goodwill arising from amalgamations prior to the 2021 Finance Act amendment qualifies for depreciation under Section 32(1) of the Income Tax Act. The ruling reinforces the Smifs Securities precedent, impacting tax treatment for corporate mergers and intangible asset valuation.

ITAT Pune rules that the Commissioner's revisionary powers under Section 263 IT Act cannot be invoked to reassess depreciation on goodwill or warranty provisions already correctly allowed by the Assessing Officer. The ruling underscores that revisionary jurisdiction requires evidence of erroneous or prejudicial orders, not mere re-examination of settled claims.