Pursuant to the order of the High Court, a company was demerged from the assessee company and all its assets and liabilities as on the appointed date were transferred to and vested in the assessee company. In the process of demerger, goodwill amounting to Rs. 275 crores, being the difference between net assets and shares to be issued, was credited by the assessee company, on which depreciation was claimed. High Court held that goodwill was an asset under Explanation 3(b) to section 32(1); the assessee company was entitled to claim depreciation on goodwill expended at the time of amalgamation of companies.  The order of the Tribunal quashing the revision order was affirmed.   SLP filed by the revenue was dismissed on account of delay of 658 days and also on merits. (AY. 2015-16)