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8. The question would be as to whether the software application, which was
acquired by the assessee would fall under Entry 5 of Part A of New Appendix
I, which states that computers including computer software are entitled to
depreciation at 60%. Note 7 of the Appendix defines the expression
'computer software' to mean any programs recorded on CD or disc, tape,
perforated media or other information storage devices.
9. The case of the Revenue is that software are licenses and that they are
intangible assets and would fall under Part B of New Appendix I, which deals
with knowhow, patents, copyrights, trademarks, licenses, franchises or any
other business or commercial rights of similar nature.