sustainable on another ground. He urged that a self-generated or self-created goodwill is not a capital asset, the transfer of which will give ... section 2(4A) of the 1922 Act, a self-created or self-generated goodwill (which it is in the instant case) would not be capital
Divatia. But the question is whether capital asset like goodwill, which is a self-generating one, can be the subject-matter of capital gains when ... suggests that self generated or self-created assets like goodwill can never be the subject matter of taxability by way of capital gains as contemplated
assessee-Hindu undivided family had purchased the goodwill. It appears that the goodwill was self-generated in the business of the Hindu undivided family ... proposition that goodwill was not taxable. Both these decisions clearly mention that the goodwill was self-generated and so it was not a capital asset
being not referable to such capital asset, and self-created or self-generated goodwill being such asset will be outside the purview of the charging ... irrelevant and inapplicable. Moreover, the argument that if the self-created or self-generated goodwill has cost nothing to the assessee, then the actual cost
being not referable to such capital asset and a self-created or self-
generated goodwill being such an asset, will be outside the purview ... capital
asset can give rise to chargeable gain. Since self-created or self-generated
goodwill is not a capital asset which could be said
asset which is transferred. In the case of a self-created or self-generated goodwill, the assessee incurs no cost in terms of money ... also one which can be improved by investing money. Self-created or self-generated goodwill is not that type of capital asset. Thirdly, even assuming
view these factors as accounting principles, ordinarily no entry of self generated goodwill finds its place in the balance sheet of any trade or business ... instructions of not making any adjustment on account of self created or self-generated goodwill while resorting to global valuation of a business
Transport Co. (P) Ltd. to submit that route permit was a self-generating asset and consideration for its transfer was not assessable as capital gains ... same effect and Raylon Silk Mills v. CIT to submit that self-generated goodwill did not attract capital gains.
7. A reference to the provisions
being not referable to such capital asset, and a self-created or self-generated goodwill being such asset, will be outside the purview ... Since we have been come to the conclusion that self-created or self-generated goodwill is not capital asset which could be said to have
value of goodwill, with the goodwill remaining constant, or as the cost of improving or adding to the quality of the goodwill. Such ... increase is really due to the fact that by further self-generation the goodwill has increased. The argument of Mr. Joshi, that the ratio
