Deduction for the cost of goodwill in the accounts

I have a client that has had a challenge from the revenue for purchased goodwill.  The revenue says the amortisation is not allowable as a deduction even though it is purchased goodwill simply because it is not a company.  HMRC says S29 of the 2002 finance act has been repealed and that sch 29 relates only to companies.

Has anyone had this challenge from the revenue and are there any suggestions on how to respond.