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We have heard the rival submissions. We find that in ground no.5 , we have held that interest paid to Head office and various branches outside India are allowable as deduction while computing the profits attributable to PE in India. Hence as agreed by the Learned AR , the ground no. 4 raised for Asst Years 2005-06 & 2006-07 and ground no. 3 raised for Asst Year 2007-08 are dismissed as not pressed.

8. HIGHER RATE OF DEPRECATION ON ATMs GROUND NO. 5 IN ASST YEAR 2005-06 GROUND NO. 5 IN ASST YEAR 2006-07 The assessee claimed depreciation on ATM at 60% being the rate of depreciation prescribed under the sub-heading "Computers including Computer Software" as given in IT Rules. The Learned AO classified ATM machines as "other office machines"