Reconstitution of firm (Sec 45(4) with 9b)

samyak jain (7 Points)

25 March 2023  
Doubt regarding self generated goodwill
In case of 45(4) applies sec 9(b)
Reconstitution of firm
Capital gain arising on difference between consideration to exiting partner and his capital balance after sec 9b is attributed to remaining assets including self generated goodwill.
Since tax has now been paid today on such attributed amount so we add the same to the cost of asset in ration of increase in value.
But in future while calculation on tax on self generated goodwill COA is considered nil. So why are we doing apportionment on self generated goodwill?