Held that the Assessee acquired 100 per cent shares of PPL from independent parties at premium, the excess of consideration paid over the net book value of assets of PPL represents goodwill attributable to the business potential and intangible attributes of PPL which vested with the assessee on amalgamation of PPL with the assessee; goodwill so recorded is thus an identifiable intangible asset acquired at cost and satisfies the conditions prescribed under s. 32(1)(ii) and, therefore, eligible for depreciation. Once the claim of depreciation was allowed by the CIT(A) in the earlier assessment years, though initially disallowed by the AO, the carry forward of the unabsorbed portion thereof becomes a vested right and the set off under S. 32(2) cannot be denied in subsequent years.(AY-2012-13, 2013-14, 2020-21 & 2022-23)