computers including
computer software. "Computer software" is defined in the ''Rule as "any
computer ... computers including
computer software. "Computer software" is defined in the ''Rule as "any
computer
boxes under
Remote terminal units/intelligent electronic devices,
computer hardware/software, router/bridges, other
required equipment and associated communication
systems for supervisory control ... following.
"Remote terminal units/intelligent electronic devices,
computer hardware/software, router/bridges, other
required equipment and associated communication
systems for supervisory control
guest house;
(iii) any office appliances including computers or computer software;
(iv) any vehicle; or
(v) any plant or machinery ... which is allowed as
deduction (whether by way of depreciation or otherwise) in computing the
income chargeable under the head "Profits
amortization of software development expenses. The A.O. had
disallowed amortization of software development expenses on
the ground that software development expenses is a capital ... which is to be included along with computers in the
block of assets for claiming depreciation. The learned
assessee to its AEs.
(b) Erroneous margin computation:
TPO failed to allocate amount
pertaining to depreciation and
erroneously reduced the cost base ... provision of IT
enabled services, Accentia is also
engaged in software development
services.
Based on the annual report, during
FY 2010-11, the management decided
actual cost of that asset so as to compute depreciation of that
9
I.T.A. Nos.354 & 338/C/2014
asset ... under the head of building, furniture, plant and machinery and computer
software which could be reduced from the cost of such assets
Logica Testing Services Pvt ltd
f) Consilient Technologies Pvt. Ltd.
g) Cybage Software Pvt Ltd
h) OFS Technologies Ltd
Ground No. 6-Erroneous data used ... marketing expenditure
adjustment, (b) research and development expenditure adjustment, (c) Depreciation
Adjustment (d) risk profile between the Appellant and the comparable companies.
Ground
Logica Testing Services Pvt ltd
f) Consilient Technologies Pvt. Ltd.
g) Cybage Software Pvt Ltd
h) OFS Technologies Ltd
Ground No. 6-Erroneous data used ... marketing expenditure
adjustment, (b) research and development expenditure adjustment, (c) Depreciation
Adjustment (d) risk profile between the Appellant and the comparable companies.
Ground
Logica Testing Services Pvt ltd
f) Consilient Technologies Pvt. Ltd.
g) Cybage Software Pvt Ltd
h) OFS Technologies Ltd
Ground No. 6-Erroneous data used ... marketing expenditure
adjustment, (b) research and development expenditure adjustment, (c) Depreciation
Adjustment (d) risk profile between the Appellant and the comparable companies.
Ground
machinery previously used.
Sub- section 3 Sales and proceeds of computer software Yes
should be received within a period of 6 months ... same
proportion as the export turnover in respect of
such computer software bears to the total
turnover of the business carried
