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“depreciation on software”

DepreciationSection 32Section 32120 judgments

The decision most relied on for depreciation on software is Techno Shares and Stocks Ltd. v. CIT (327 ITR 323), cited in 130 judgments on BharatTax.

Leading authorities on depreciation on software

Techno Shares and Stocks Ltd. v. CIT
327 ITR 323 · 2010 · Supreme Court
130
citing judgments

Membership rights and business contracts, as 'business or commercial rights of similar nature' to a license or franchise, qualify as intangible assets eligible for depreciation under Section 32(1)(ii) of the Income-tax Act.

Amway India Enterprises v. DCIT
111 ITD 112 · 2008 · ITAT
127
citing judgments

Depreciation is allowable on computer software, including software licenses, at the rate of 60%.

CIT v. IBM India Ltd.
357 ITR 88 · 2013 · High Court
88
citing judgments

Expenditure on application software, which enhances business efficiency and requires a computer system to function, constitutes revenue expenditure rather than acquisition of a capital asset, even if it provides an enduring benefit.

Hindustan Unilever Ltd. v. DCIT
325 ITR 102 · 2010 · High Court
62
citing judgments

The deduction under Section 10A/10B is a deduction, not an exemption, and must be given effect to at the stage of computing the profits and gains of business. For this purpose, commercial profits mean profits without adjustment of depreciation as per the Income Tax Act.

Kerala Vision Ltd. v. ACIT (
35 Taxmann.com 463 · 2013 · ITAT
52
citing judgments

Transactions carried out on the purchase of off-the-shelf software prior to the jurisdictional High Court's decision in CIT v. Samsung Electronics Co. Ltd. (October 15, 2011) are not liable for Tax Deducted at Source (TDS).

Thiru Arooran Sugar Ltd. v. DCIT
350 ITR 324 · 2013 · High Court
44
citing judgments

A deduction for interest expense on borrowed funds used for interest-free advances to group companies is permissible only if the assessee establishes these advances were from surplus funds. The decision further clarifies eligibility for depreciation on intangible assets like non-compete fees, software, goodwill, and commercial rights under section 32(1)(ii), often arising from a slump sale.

SKOL Breweries Ltd. v. ACIT
29 Taxmann.com 111 · 2013 · ITAT
33
citing judgments

Section 40(a)(i)/(ia) of the Income Tax Act, 1961, pertains to outgoing revenue expenditure and does not apply to capital expenditure, meaning depreciation cannot be disallowed under these provisions for capital expenses, such as software purchases.

CIT v. Computer Age Management Services (P.) Ltd.
109 Taxmann.com 134 · 2019 · High Court
27
citing judgments

Software integrated with a computer system is eligible for the same rate of depreciation as the computer system itself.

Judgments citing depreciation on software

DCIT, Cir 8(2) (1), Mumbai vs. M/S. Ogilvy and Mather Pvt. Ltd, Mumbai

In the result, the In the result, the cross appeals of the assessee and Revenue of the assessee and Revenue are dismissed

ITA 1637/MUM/2021[2012-13]Status: DisposedITAT Mumbai29 May 2023AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry ()

For Appellant: Mr. Ajit Shah/Hetal Sangani
Section 37

made us 154 of the Ld. CIT(A) erred in delegating the addition made us 154 of the Act on the ground that depreciation on software is allowable Act on the ground that depreciation on software is allowable Act on the ground that depreciation on software is allowable ... assessee claimed depreciation on purpose of the income tax, the assessee claimed depreciation on purpose of the income tax, the assessee claimed depreciation on software expenses at the rate of the 60% of written down value.The software expenses at the rate of the 60% of written down software expenses

Ogilvy and Mather P. Ltd, Mumbai vs. The Asstt. CIT-8(2)(1), Mumbai

In the result, the In the result, the cross appeals of the assessee and Revenue of the assessee and Revenue are dismissed

ITA 1326/MUM/2021[2016-17]Status: DisposedITAT Mumbai29 May 2023AY 2016-17

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry ()

For Appellant: Mr. Ajit Shah/Hetal Sangani
Section 37

made us 154 of the Ld. CIT(A) erred in delegating the addition made us 154 of the Act on the ground that depreciation on software is allowable Act on the ground that depreciation on software is allowable Act on the ground that depreciation on software is allowable ... assessee claimed depreciation on purpose of the income tax, the assessee claimed depreciation on purpose of the income tax, the assessee claimed depreciation on software expenses at the rate of the 60% of written down value.The software expenses at the rate of the 60% of written down software expenses

Ogily and Mather P. Ltd., Mumbai vs. The Asst. CIT -8(2)(1), Mumbai

In the result, the In the result, the cross appeals of the assessee and Revenue of the assessee and Revenue are dismissed

ITA 1325/MUM/2021[2013-14]Status: DisposedITAT Mumbai29 May 2023AY 2013-14

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry ()

For Appellant: Mr. Ajit Shah/Hetal Sangani
Section 37

made us 154 of the Ld. CIT(A) erred in delegating the addition made us 154 of the Act on the ground that depreciation on software is allowable Act on the ground that depreciation on software is allowable Act on the ground that depreciation on software is allowable ... assessee claimed depreciation on purpose of the income tax, the assessee claimed depreciation on purpose of the income tax, the assessee claimed depreciation on software expenses at the rate of the 60% of written down value.The software expenses at the rate of the 60% of written down software expenses

Ogilvy and Mather P. Ltd., Mumbai vs. The Asst. CIT-8(2)(1), Mumbai

In the result, the In the result, the cross appeals of the assessee and Revenue of the assessee and Revenue are dismissed

ITA 1324/MUM/2021[2012-13]Status: DisposedITAT Mumbai29 May 2023AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry ()

For Appellant: Mr. Ajit Shah/Hetal Sangani
Section 37

made us 154 of the Ld. CIT(A) erred in delegating the addition made us 154 of the Act on the ground that depreciation on software is allowable Act on the ground that depreciation on software is allowable Act on the ground that depreciation on software is allowable ... assessee claimed depreciation on purpose of the income tax, the assessee claimed depreciation on purpose of the income tax, the assessee claimed depreciation on software expenses at the rate of the 60% of written down value.The software expenses at the rate of the 60% of written down software expenses

DCIT-2(3), Mumbai vs. M/S. Zensar Technologies Ltd., Mumbai

In the result, the appeal is partly allowed

ITA 5653/MUM/2009[2004-05]Status: DisposedITAT Mumbai19 Apr 2023AY 2004-05

Bench: Amit Shukla () & Ms. Padmavathy S. ()

Section 10ASection 80Section 92

uphold the decision of the CIT(A) to allow the deduction under section 80HHE and this ground of the Revenue is dismissed. 22. Depreciation on Software Expenses (Ground No.4) 23. The Assessee contended before the Ld.CIT(A) that the Assessing Officer did not allow depreciation on the WDV of Software

M/S Harmony Media Pvt Ltd., Mumbai vs. ITO 5 (1)(4), Mumbai

In the result, the appeal filed by the assessee in ITA No

ITA 7116/MUM/2019[2015-16]Status: DisposedITAT Mumbai15 Dec 2022AY 2015-16

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Smt. Usha Gaikwad
Section 143(3)Section 250

depreciation of Rs.1,22,31,226/-. 4. The CIT (A) erred in confirming the order of the A.O. in restricting the rate of depreciation on software to 25% instead of 60%. 5. CIT (A) erred in not considering the written submissions of the assessee Company in its proper perspective ... depreciation claimed on addition of new assets to Rs.37,61,496/- @ 15% flat and disallowing balance depreciation of Rs.1,22,31,226/- and depreciation on software restricted to 25% instead of 60%. It is observed that the assessee has made addition on fixed assets namely computer and software, furniture

M/S Harmony Media Pvt Ltd., Mumbai vs. ITO 5 (1)(4), Mumbai

In the result, the appeal filed by the assessee in ITA No

ITA 7115/MUM/2019[2014-15]Status: DisposedITAT Mumbai15 Dec 2022AY 2014-15

Bench: Shri Om Prakash Kant, Am & Ms. Kavitha Rajagopal, Jm

For Respondent: Smt. Usha Gaikwad
Section 143(3)Section 250

depreciation of Rs.1,22,31,226/-. 4. The CIT (A) erred in confirming the order of the A.O. in restricting the rate of depreciation on software to 25% instead of 60%. 5. CIT (A) erred in not considering the written submissions of the assessee Company in its proper perspective ... depreciation claimed on addition of new assets to Rs.37,61,496/- @ 15% flat and disallowing balance depreciation of Rs.1,22,31,226/- and depreciation on software restricted to 25% instead of 60%. It is observed that the assessee has made addition on fixed assets namely computer and software, furniture

Roca Bathroom Products Private Limited, Chennai vs. DCIT Ltu-1, Chennai

The appeal stand partly allowed to the extent indicated in the order

ITA 2976/CHNY/2017[2013-14]Status: DisposedITAT Chennai30 Nov 2022AY 2013-14

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri N. V. Balaji (Advocate) – Ld. ARFor Respondent: Dr. S. Palanikumar (CIT) – Ld. DR
Section 143(3)Section 144C(5)Section 92C

principles prescribed under the Accounting Standards issued by the ICAI. 6. Erred in law and on facts in disallowing the claim of depreciation on software amounting at the rate of 60 percent restricting the same to 25 percent applicable to the block 'intangible assets' amounting ... Lacs short deduction of taxes 4 Provision created towards slow / non- 95.94 Lacs moving and obsolete inventory 5. Depreciation on software 46.47 Lacs 6. Provision for VAT assessment demand 9.00 Lacs 3. The Ld.AR advanced arguments and placed on record earlier orders of the Tribunal in support of submissions

M/S Infosys Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee stands partly allowed

ITA 718/BANG/2017[2012-13]Status: DisposedITAT Bangalore28 Nov 2022AY 2012-13

Bench: Shri Chandra Poojaria & Smt. Beena Pillaiassessment Appeal No. Appellant Respondent Year M/S. Infosys Ltd., The Assistant Electronic City, Commissioner It(Tp)A No. Hosur Road, Of Income Tax, 2012-13 718/Bang/2017 Bangalore – 560 Circle – 100. 3(1)(1), Pan: Bangalore. Aaaci4798L : Shri Padamchand Khincha, Assessee By Ca : Shri K.V. Arvind & Shri Dilip, Revenue By Standing Counsels For Dept. Date Of Hearing : 15-09-2022 Date Of Pronouncement : 28-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Final Assessment Order Dated 28/02/2017 Passed By The Ld.Acit, Circle – 3(1)(1), Bangalore For A.Y. 2012-13 On Following Grounds Of Appeal: General & Legal Grounds 1. The Order Passed By The Learned Assessing Officer & The Directions Of Hon’Ble Drp To The Extent Prejudicial To The Appellant Is Bad In Law & Liable To Be Quashed. Grounds On Denial Of Deduction Claimed Under Section 10Aa In Respect Of 4 Sez Units Viz., Chennai – Unit 1, Chandigarh, Mangalore - Unit 1 & Pune Unit 1 2. The Learned Assessing Officer Has Erred In Denying Deduction Claimed Under Section 10Aa In The Return Of Income Totally Amounting To Rs. 2227,82,65,630 In Respect

Section 10ASection 14ASection 2Section 2(24)Section 40

contrary to law. 11.6. Without prejudice, the Ld.AR also submitted that in the event the expenditure is held to be capital in nature, depreciation on software expenses is to be allowed at 60%. The Ld.AR relied on decision of coordinate bench of this Tribunal in assessee’s own case

Infiniti Wholesale Ltd ( Formerly Knwon As Woolwonths Wholesale (India) P.Ltd), Mumbai vs. Asst CIT Cir 8(3), Mumbai

In the result, appeal filed by the Appellant is partly allowed

ITA 7718/MUM/2012[2008-09]Status: DisposedITAT Mumbai13 Oct 2022AY 2008-09
For Appellant: Shri Nitesh JoshiFor Respondent: Michael Jerald
Section 143(3)Section 144CSection 144C(5)Section 92C

asset ii) Software expenses 80,07,197 iii) Different in AIR 24,855 7,70,53,980 (-) 11,16,96,313 Less Depreciation on software exp. 48,04,318 Capitalized @ 60% Total taxable income (-) 10,68,91,995 5 Assessment Year: 2008-09 6. Being aggrieved, the Appellant ... Though, in the computation table, the Assessing Officer has correctly stated that as under: (-) 11,16,96,313/- Less depreciation on software @ 60% 48,04,318/- The Assessing Officer has incorrectly added the depreciation amount of INR 48,04,318/- to arrive at incorrect figure of loss

Addl CIT RG 7(1), Mumbai vs. Peninsula Land Ltd, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 4136/MUM/2012[2008-09]Status: DisposedITAT Mumbai12 Oct 2022AY 2008-09

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

expenses be deleted. 4. Without prejudice to the above, the Appellant prays that the percentage of disallowance be appropriately reduced. GROUND III: Restricting depreciation on software expenses: 1. On the facts and in the circumstances of the case and in law, the CIT(A) erred in upholding the action ... restricting the depreciation on software to 25% amounting to Rs.5,67,707 as against 60% considered by the Appellant amounting to Rs. 13,62,496/- thereby disallowing a sum of Rs.7,94,789/- on the alleged ground that payments were made towards license fees for software. 2. He failed

Peninsula Land Ltd, Mumbai vs. Addl CIT 7(1), Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 3717/MUM/2012[2008-09]Status: DisposedITAT Mumbai12 Oct 2022AY 2008-09

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

expenses be deleted. 4. Without prejudice to the above, the Appellant prays that the percentage of disallowance be appropriately reduced. GROUND III: Restricting depreciation on software expenses: 1. On the facts and in the circumstances of the case and in law, the CIT(A) erred in upholding the action ... restricting the depreciation on software to 25% amounting to Rs.5,67,707 as against 60% considered by the Appellant amounting to Rs. 13,62,496/- thereby disallowing a sum of Rs.7,94,789/- on the alleged ground that payments were made towards license fees for software. 2. He failed

Hewlett Packard (India) Software Operation Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 413/BANG/2022[2017-18]Status: DisposedITAT Bangalore03 Oct 2022AY 2017-18

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.413/Bang/2022 Assessment Year: 2017-18

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Shri Sumer Singh Meena, D.R
Section 192Section 195Section 37Section 40Section 92C

NFAC erred in not considering the Hon’ble DRP’s direction and not allowing the claim of consequential depreciation on software expenses (disallowed by the AO in the earlier years considering the same as capital in nature) amounting to INR 3,970,944. 3.5 The NFAC erred in levying interest ... fresh consideration. 9.3. Ground No.3.4 is with regard to non-following the direction of the Ld. DRP to grant consequent depreciation on software. This issue is also remitted to the file of AO to grant appropriate depreciation as per the direction of Ld. DRP. 9.4. Ground Nos.3.5 & 3.6 are regarding

Novartis India Ltd, Mumbai vs. Addl CIT RG 7(1), Mumbai

In the result, appeal filed by the assessee is partly allowed as stated above

ITA 7644/MUM/2012[2008-09]Status: DisposedITAT Mumbai28 Sept 2022AY 2008-09

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Novartis India Limited Addl. Cit, Range 7(1) V. Aayakar Bhavan, M.K. Road Sandoz House, Dr. Annie Besant Road Worli, Mumbai - 400018 Mumbai Pan: Aaach2914F Appellant Respondent Assessee Represented By : Shri Rajan Vora & Shri Pranay Gandhi Revenue Represented By : Shri Rajneesh Yadav

Section 144C(5)Section 35DSection 92C(2)

ground that the same is capital expenditure of an enduring nature. (b) The learned AO further erred in disallowing depreciation on software expenses disallowed in earlier years relating to the demerged unit. GROUND NO. 5 (a) The learned AO erred in making an addition

M/S Bosch Limited, Bangalore vs. Assistant Commissioner of Income Tax Ltu Circle-1, Bangalore

In the result, appeal of the assessee is partly allowed

ITA 1629/BANG/2018[2013-14]Status: DisposedITAT Bangalore13 Sept 2022AY 2013-14

Bench: Shri N.V. Vasudevan & Ms. Padmavathy Sassessment Year : 2013-14 Bosch Limited, Vs. The Assistant Commissioner Hosur Road, Adugodi, Of Income Tax, Ltu, Bangalore – 560 030. Circle 1, Pan: Aaacm 9840P Bangalore. Appellant Respondent Appellant By : Shri Percy Pardiwala, Advocate Respondent By : Shri V S Chakrapani, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 01.09.2022 Date Of Pronouncement : 13.09.2022 O R D E R Per Padmavathy S.2. This Appeal Is Against The Order Of The Cit(Appeals), Bangalore-9, Bangalore Dated 31.3.2018 For The Assessment Year 2013- 14. 3. The Assessee Raised Grounds Pertaining To The Following Issues:- Deduction U/S. 35(2Ab) Computed On Net Expenditure As Opposed To Gross Expenditure Disallowance Of Provision For Bad & Doubtful Debts I) Disallowance Of Provision For Long Term Service Award Disallowance Of Expenditure U/S. 14A Of The Act Ii) Page 2 Of 67

For Appellant: Shri Percy Pardiwala, AdvocateFor Respondent: Shri V S Chakrapani, CIT(DR)(ITAT), Bengaluru
Section 14ASection 35Section 37Section 43BSection 80J

years till a higher version is purchased is to be treated as capital, as it is enduring benefit. The law provides for 60% depreciation on software considering its life of 2-3 years. So, these software expenses cannot be considered as revenue in nature. 82. However, as regards License

Textron India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Bangalore

In the result, the appeal filed by the assessee stands allowed on the grounds argued by assessee and other issues that has not been pressed is kept open

ITA 711/BANG/2017[2012-13]Status: DisposedITAT Bangalore26 Aug 2022AY 2012-13
For Appellant: Shri Sumit Khurana, CAFor Respondent: Shri V.S. Chakrapani, CIT-DR
Section 92C(3)(c)Section 92D

direct the Ld.AO to delete the disallowance made. Accordingly this ground stands allowed. 31. Ground no. 17 is in respect of disallowance of depreciation on software that is capitalised by assessee. The assessee during the previous year has purchased software amounting to Rs.7,62,38,026 which has been treated ... books) being downloadable software and software's purchased in the form of media like ) CD and DVD. The assessee claimed the depreciation on software purchases amounting to Rs. 13,71,275. Page 24 of 28 IT(TP)A No. 711/Bang/2017 32. Identical issue has been considered by Coordinate Bench

M/S Infineon Technologies India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(1), Bangalore

ITA 3355/BANG/2018[2014-15]Status: DisposedITAT Bangalore25 Aug 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 3355/Bang/2018 Assessment Year : 2014-15 M/S. Infineon Technologies India Pvt. The Deputy Ltd., Commissioner Of 9Th Floor, Prestige Income Tax, Thirulakshmi, Circle – 3(1)(1), No. 11, Mg Road, Vs. Bangalore. Bangalore. Pan: Aabcs6967N Appellant Respondent : Shri K.R. Vasudevan, Assessee By Advocate : Shri Sumer Singh Meena, Revenue By Cit Dr Date Of Hearing : 12-07-2022 Date Of Pronouncement : 25-08-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Assessment Order Dated 26/10/2018 By The Ld.Dcit, Circle – 3(1)(1), Bangalore On Following Grounds Of Appeal: “A. Transfer Pricing The Grounds Mentioned Hereinafter Are Without Prejudice To One Another. 1. The Learned Assessing Officer ('Learned Ao'), Learned Transfer Pricing Officer ('Learned Tpo') & The Honourable Dispute Resolution Panel ('Hon'Ble Drp') Grossly Erred In Adjusting The Transfer Price By Inr 9,56,93,721/- With Respect To The International

For Respondent: Shri K.R. Vasudevan
Section 92C

cross-charged by Infineon Germany are not in the nature of FTS under the Act and the applicable tax treaty. 27. Disallowance of depreciation on software expenses: i. The Learned AO and the HOn'ble DRP have erred in disallowing a sum of Rs. 1,125,986 as excess depreciation ... have failed to consider a higher opening WDV as computed by the Learned AO on account of disallowance of excess depreciation on software expense in AY 2013-14, for the computation of depreciation for the subject year. 28. Interest under section 234B of the Act: The Learned AO has erred

Thermo Fisher Scientific India P.Ltd, Mumbai vs. DCIT 10(3), Mumbai

In the result, all the three additional grounds mentioned above are treated as allowed for statistical purposes

ITA 2701/MUM/2014[2009-10]Status: DisposedITAT Mumbai24 Aug 2022AY 2009-10
Section 43(6)(c)

Goodwill purchased from Glaxosmithkline Pharmaceuticals Ltd. 12. Ground 12 - Allowance of higher brought forward unabsorbed depreciation of AY 2008-09 relating to depreciation on software expenses 12.1 On the facts and in the circumstances of the case and in law, the learned DCIT erred in not allowing higher brought forward

M/S Harman International (India) Pvt Ltd, Bangalore vs. Deputy Commissioner of Income Tax Circle-3(1)(2), Bangalore

In the result, the appeal by the assessee is partly allowed

ITA 49/BANG/2019[2014-15]Status: DisposedITAT Bangalore30 Jun 2022AY 2014-15

Bench: Shri N. V. Vasudevan & Ms. Padmavathy Sit(Tp)A No.49/Bang/2019 Assessment Year : 2014-15 M/S. Harman Connected Services Vs. Deputy Commissioner Of Corporation India Private Limited, Income Tax, 4A, Jupiter, Prestige Technology Park, Circle - 3(1)(2), Sarjapur, Marathahalli Road, Bengaluru. Kadubeesanahalli Village, Bengaluru – 560 103. Pan: Aacch 1585 J Appellant Respondent Assessee By : Shri. T. Suryanarayana, Senior Advocate Revenue By : Dr. Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 27.06.2022 Date Of Pronouncement : 30.06.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. T. Suryanarayana, Senior AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92Section 92C

dealt with identical issue and has held as follows: “18. Arguing on fourth common ground, which is on restriction of the claim of depreciation on software, ld. Authorised Representative submitted that ld. Assessing Officer had restricted the depreciation to 25% against 60% available for computer systems. According to ld. Authorised

M/S. Nicholas Piramal India Ltd, Mumbai vs. The ACIT Cur 7(1)

In the result, the appeal filed by the revenue is dismissed and the appeal filed by the assessee is partly allowed for statistical purposes

ITA 769/MUM/2008[2004-2005]Status: DisposedITAT Mumbai28 Jun 2022AY 2004-2005

Bench: Shri Pavan Kumar Gadale & Shri S Rifaur Rahmanpiramal Enterprises Ltd Vs. Acit, Circle – 7(1) (Formerly Known As Aayakar Bhavan Piramal Healthcare Ltd) Mumbai – 400020. (Before Known As Nicholas Piramal Ind) Piramal Tower, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400013. Pan/Gir No. : Aaacn4538P Appellant .. Respondent Dcit, Circle – 7(1) Vs. Piramal Enterprises Ltd Aayakar Bhyavan (Formerly Known As Mumbai – 400 020. Piramal Healthcare Ltd) (Before Known As Nicholas Piramal Ind) Piramal Tower, Ganpatrao Kadam Marg, Lower Parel, Mumbai – 400 013. Pan/Gir No. : Aaacn4538P Assessee By : Mr.Ronak Doshi & Ms.Manshi Padhiyar.Ar Revenue By : Mr.S.N.Kabra.Dr

For Appellant: Mr.Ronak Doshi &For Respondent: Mr.S.N.Kabra.DR
Section 143(3)Section 145Section 32Section 35Section 80

depreciation @60%. We find there is nothing remains in the ground of appeal as it become in fructuous due to grant of higher depreciation on software and the ground of appeal of the revenue is dismissed. ITA No. 769 & 1954/Mum/2008 M/s Nicholas Piramal India Ltd, Mumbai. 13. The third disputed ... dated 15.01.2013]. Apart there from, we find that further in the following cases also the coordinate benches of the Tribunal had concluded that depreciation on software expenses is allowable @ 60%: “(i) Sriniovasa Rsorts Vs. ACIT (41 taxmann.com 350) (Hyd-Trib) (ii). Ushodaya Enterprises Limited 938 ITR (T) 148 ) (Hyd-Trib