penalty, without appreciating that the disallowance of additional
depreciation in respect of computer software 'Primavera' was itself,
in the first place ... addition on account of disallowance of additional
depreciation on computer software
3. Simultaneously, penalty proceeding
depreciation is allowable "on computers including
computer software" @60% in terms of Item 4 under Machinery
and Plant (Item ... Assessing officer restricted the grant of depreciation @60% to
computers and allowed depreciation on software at only 25%
which is the general rate
rate of
depreciation applicable on such assets. As per rates of depreciation
applicable for A.Y.2008-09, computer software was eligible ... neither be said to be "computers" nor "computer software".
Depreciation rate at the rate
computer software" is used meaning thereby the computer
software is different from article or things. The AO concluded that
computer ... Further, the AO observed that computers and computer software are
depreciated at higher rates than plant and machinery, which suggests
that
computer software" is used meaning thereby the computer
software is different from article or things. The AO concluded that
computer ... Further, the AO observed that computers and computer software are
depreciated at higher rates than plant and machinery, which suggests
that
rate specified for the block computers including computer
software.
40. The Ld.AO restricted the depreciation on software purchased ... 2013
wherein computer software was also included along with
computers eligible for depreciation at 60%.
The Ld.AR also submitted that
hardware and software.
Anything that can be stored electronically is computer software and machines
used to run the software is called hardware. Thus ... customers were nothing but computer softwares. These education
softwares were a kind of computer software the primary purpose of which
Procter & Gamble Hygiene & Health Care ... vs Assessee on 17 January, 2012
IN THE
therefore it requires continuous
upgrading.
17. Heard rival submissions, depreciation on computer software is
no more res integra as this issue is settled ... software was used along with
computer and when their functions were integrated with computer,
such hardware or software would be termed
depreciation on computer software for the reason that the assessee has not
deducted tax at source on computer software and held that ... made towards depreciation
on computer software on the ground that no TDS was deducted on the
payments made towards computer software
