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Amalgamation Goodwill Eligible for Depreciation; Notional Interest on AE Receivables Deleted: ITAT Delhi
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ITAT Delhitax

Amalgamation Goodwill Eligible for Depreciation; Notional Interest on AE Receivables Deleted: ITAT Delhi

July 5, 2026

The ITAT Delhi ruled that goodwill from amalgamation qualifies as a depreciable intangible asset, and deleted the TP adjustment for overdue AE receivables.

ITAT Delhi Rules on Amalgamation Goodwill and Receivables

The ITAT Delhi has affirmed that goodwill arising from amalgamations qualifies as a depreciable intangible asset, eligible for depreciation under the Income Tax Act. This decision reinforces the understanding of how goodwill should be treated in income tax assessments.

Additionally, the tribunal deleted the transfer pricing adjustment imposed on overdue receivables from associated enterprises, emphasizing the need for accurate accounting treatment and verification of outstanding receivables before imposing tax adjustments.

This ruling is significant for practitioners dealing with mergers and acquisitions, as it establishes clear guidelines on the tax treatment of goodwill stemming from amalgamations and ensures that businesses understand their entitlement to depreciation on intangible assets.

Citations

  • ITAT Delhi (2026) TaxGuru 05
Source:ITAT Delhi
Practice Areas:tax