DY. COMMISSIONER OF INCOME TAX , CIRCLE-2(2), HYDERABAD vs. HSBC ELECTRONIC DATA PROCESSING INDIA PRIVATE LIMITED, , HYDERABAD
In the result, the appeal filed by the Revenue is dismissed
ITA 1632/HYD/2017[2010-11]Status: DisposedITAT Hyderabad05 Aug 2024AY 2010-11
Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia
For Appellant: Shri Rajan Vora, C.AFor Respondent: : Shri Kumar Pranav, CIT-DR
Section 10ASection 115Section 115JSection 251(1)(a)Section 37(1)Section 41(1)
…ncurred for running the business more efficiently and hence the same qualifies as revenue expenditure. Assessee in support relied on the decisions in the case of Asahi India Safety Glass (245 CTR 529), Southern Roadways Ltd., (183 Taxmann 234), IBM India Ltd (290 ITR 183). Assessing Officer, after considering the explanation of the assessee and after examining the nature of software purchased, held that the purchases are capital in nature and further held that the same is eligible for depreciation @ 25%. During the appellate proceedings it is submitted by the assessee that they are in ITES business and use variou…