https://www.taxtmi.com/caselaws?id=297246 The Tribunal dismissed the Revenue's appeal against the CIT(A) order allowing depreciation on computer software at 60%, rejecting the argument for restriction to 25%. The re-opening of assessment u/s 148 was deemed invalid beyond 4 years as it was solely based on a change of opinion without fresh facts, following the decision in Kelvinator of India Ltd. Despite the lack of a speaking order on objections, the re-opening was quashed as all necessary facts were available during the original assessment, leading to the dismissal of the Revenue's appeal. en-us Fri, 10 Feb 2012 00:00:00 +0530 Tue, 24 Aug 2021 16:12:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=297246 The Tribunal dismissed the Revenue's appeal against the CIT(A) order allowing depreciation on computer software at 60%, rejecting the argument for restriction to 25%. The re-opening of assessment u/s 148 was deemed invalid beyond 4 years as it was solely based on a change of opinion without fresh facts, following the decision in Kelvinator of India Ltd. Despite the lack of a speaking order on objections, the re-opening was quashed as all necessary facts were available during the original assessment, leading to the dismissal of the Revenue's appeal. Case-Laws Income Tax Fri, 10 Feb 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=297246