made by the AO on
account of depreciation on computer software.
4. The appellant craves leave, to add, alter or amend any
ground ... part of computer system and, therefore, depreciation @
60% was to be allowed. Moreover, rate of depreciation of computer
software has been
Procter & Gamble Hygiene & Health Care ... vs Assessee on 17 January, 2012
IN THE
depreciation prescribed for computer software. This clearly showed
that expenditure for computer software, was in the nature of capital
outgo. Omission ... during the period. The Statute
itself allows 60% of depreciation on computer / software which
shows that the enduring benefit need not be spread
onwards, on "computer including computer
software" depreciation has to be allowed to the tune of 60%. With the inclusion ... treated the
expenditure on acquiring the computer software as expenditure of capital
nature and rightly allowed depreciation as per rules
amendment rate of depreciation for computers was made to
read "Computers including computer software (See note ... treated as capital expenditure. However, at the same time
computer software depreciation has to be allowed at 60%.
Therefore, we set aside
including computer software 60%
(see Note 7 below Table) ".
Note 7 states that the computer software means any computer ... part of computers and since there
is no specific item of computer software in the depreciation
schedule for the impugned
alternative claim that if the
expenditure on computer software is treated as capital expenditure, depreciation
thereon should be allowed, it is observed that ... issue relating to assessee's alternative claim for depreciation on computer software
if the same is treated as capital expenditure
amendment, computer including computer software were
included in the block of assets on which 60% depreciation was made
allowable, in other ... words, expenditure incurred for acquisition of computer
software has to be capitalized statutorily on which depreciation was
allowable
computers including computer software" indicated
in Appendix-I of the Income Tax Rules providing for depreciation
rates.
Let
this Appeal
profit of the undertaking engaged in the export of computer software. The
unabsorbed depreciation of ineligible units can also ... undertaking from the export of articles or things or computer
software is required to be allowed from the total income of the
assessee
