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3. failed to appreciate that the assessment order was neither erroneous nor prejudicial to the interest of the revenue and thus order u/s 263 is bad in law, illegal, ultra-vires, in excess of and/or in want of jurisdiction and otherwise void;

ITA No. 1010/MUM/2021

Assessment Year: 2015-16 Claim of depreciation on Computer including Computer software

4. The assessee, in reply, submitted as follows:-

4. Assessee in its reply submitted that, "The Assessee vide its submission dated 27th June 2017 during the course of assessment proceedings submitted facts related to depreciation. Further, the supporting invoices for addition to Fixed Assets were also submitted by the Company. Hence AO has verified this aspect. For the purpose of the Income Tax Act, the Company has correctly capitalized hardware and software under "Computers including computer software" which forms part of the "Plant and Machinery"