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Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciation block.
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Reinsurance premiums ceded to a non-resident reinsurer should not be disallowed under the insurance-business computation regime merely on an Assessing Officer's inferred regulatory breach where the sectoral regulator has examined the arrangement and raised no objection. A tax disallowance requires an established regulatory violation with tax consequences, rather than an independent technical interpretation of regulatory correspondence. Independently acquired enterprise application software falls within the depreciation entry for computers including computer software. The entry does not distinguish operating from application software or software bought with hardware from separately licensed software; licensing does not convert it into an intangible commercial or intellectual property right. The applicable computer-software depreciation rate remains subject to verification of first use.
Reinsurance premiums ceded to a non-resident reinsurer should not be disallowed under the insurance-business computation regime merely on an Assessing Officer's inferred regulatory breach where the sectoral regulator has examined the arrangement and raised no objection. A tax disallowance requires an established regulatory violation with tax consequences, rather than an independent technical interpretation of regulatory correspondence. Independently acquired enterprise application software falls within the depreciation entry for computers including computer software. The entry does not distinguish operating from application software or software bought with hardware from separately licensed software; licensing does not convert it into an intangible commercial or intellectual property right. The applicable computer-software depreciation rate remains subject to verification of first use.
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