Owned Computer Hardware, System Software,
furniture, fixtures and fittings.
2. Leased Computer Hardware including system
Software. 2.50
3. Computer ... Assets Depreciation Rate of Depreciation Rate of
claimed by depreciation as per WDV of depreciation
the assessee Mukund
Ltd.(allowable)
1. Computer excluding
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
Container Corporation Of India Ltd., ... vs Dcit, New Delhi on 19 January, 2017
INCOME TAX
Page 2 of 6
Claim of depreciation on Computer including Computer software
4. failed to appreciate that the addition / classification ... Company has correctly capitalized hardware and software under
"Computers including computer software" which forms part of the "Plant
income
arising from an international transaction shall be computed having
regard to the arm's length price. In this appeal ... disallowances in addition to the TP adjustments:-
(i) Disallowance of depreciation on computer peripherals
amounting to Rs. 3,19,328/-
(ii) Disallowance
depreciation. The plant and machinery is entitled
for depreciation at the rate of 15% whereas "computer" including software is
entitled ... computer" or a "computer software or
peripheral of computer, is approved, and it is held that film
confirming of disallowance of depreciation of Rs. 73,483/- on inverters
connected to computer is concerned, As per the definition of block ... Income Tax Rule, 1962, New Appendix 1, Computers including
computer software means any compute program recorded on any disc
M/S. Naramada Infrastructure ... vs The Assistant Commissioner Of Income ... on 29 December, 2022
Bench
assessee itself for Assessment Year 2007-08. The claim
for depreciation on software was also allowed by
following its previous order in the case ... Assessment Years 2004-05 and 2007-08 pertaining to
depreciation claimed on software, which was treated as
royalty. However, it is pointed out that
claimed and been actually allowed the deduction in respect
of depreciation for each of the relevant assessment year.
(7) The provisions of sub-section ... begins
to manufacture or produce articles or things or computer
software during the previous year relevant to the assessment year
commencing