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Showing contexts for: computer includes computer software in M/S. Infineon Technologies India Pvt ... vs Deputy Commissioner Of Income Tax, ... on 31 March, 2022Matching Fragments
Accordingly we direct the Ld.AO to delete the addition made on this issue.
Accordingly Ground no.15 raised by assessee stands allowed.
39. Ground No.16 is in respect of disallowance of depreciation and software expenses.
The Ld.AR submitted that assessee during the year had disallowed ₹ 7,43,893/- as capital expenses debited to profit and loss account in its return of income. He submitted that the software purchased was capitalise and depreciation was claimed at the rate specified for the block computers including computer software.
41. The Ld.AR placed reliance on the decision of Hon'ble Special Bench Delhi Tribunal in case of Amway India Enterprises reported at 111 ITD 112 and the decision of coordinate bench of the Tribunal in case of IBM India (P.) Ltd., reported 83 ITR(T) 24 (2020) and decision of Infosys Ltd in IT(TP)A.No. 102 and 233/B/2013 wherein computer software was also included along with computers eligible for depreciation at 60%. The Ld.AR also submitted that the decision of Hon'ble Special Bench Delhi Tribunal in case of Amway India Enterprises On the contrary the Ld.SR.DR relied on orders passed by authorities below.