insurance charge of Rs.1,17,87,049 from export
turnover while computing 10AA deduction (Grounds 2 to 2.8)
(ii) Exclusion ... that the assessee is a company
engaged in the business of software development and allied activities.
The assessee filed return of income on 29.11.2013 declaring
Google India Private Limited, ... vs The Deputy Commissioner Of Income Tax ... on 11 May, 2018
Biocon Research Limited, Bangalore vs Cit(A) I, Bangalore on 18 December, 2017
IN THE
following the judicial precedents.
9. Restriction of depreciation on computer software from 60 per cent to
25 per cent
9.1. The learned ACIT ... restricting depreciation claim to a lower rate of 25% as against the Appellant's
claim for depreciation on computer software
Expenditure on software imports:
21. The learned AO erred in disallowing depreciation of Rs. 57,38,83,507/- on
imported software products used in-house ... depreciation in computing the total income.
23. The learned authorities below erred in proceeding on the basis that
payment for imported software
computers including computer software. Note-7 states that
computer software means any computer programme
recorded ... Appendix I, which
states that computers including computer software are
entitled to depreciation at 60%. Note 7 of the Appendix
defines
computer software. The AO
treated the servers as not part of the computers but treated it as Plant &
Machinery. Depreciation ... Software' and are eligible for depreciation at the
rate of 60%; Therefore depreciation on servers will be allowed at the rate
applicable to computers
computer including computer
software' indicating that the computer software which is eligible for
depreciation ... says that computer
included computer software. Note 7 of the Appendix, defines computer
software as any computer
Hewlett - Packard Global Soft Private ... vs Assessee on 23 September, 2013
IN THE INCOME TAX
Samsung Electronics Company Ltd. vs Income Tax Officer on 18 February, 2005
Equivalent citations: [2005
