https://www.taxtmi.com/caselaws?id=308195 Section 40(a)(i) and section 40(a)(ia) do not apply to depreciation claimed under section 32 on software expenditure that was capitalised. The Tribunal applied the High Court's reasoning that those disallowance provisions target revenue outgoings on which tax was deductible at source, whereas depreciation is a statutory allowance on an eligible asset and is not itself an expenditure outgoing. Because only depreciation was claimed on the capitalised software cost, no disallowance under section 40(a)(i) or section 40(a)(ia) was attracted, and the assessee succeeded. en-us Thu, 05 Aug 2021 00:00:00 +0530 Tue, 06 Jun 2023 20:48:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=308195 Section 40(a)(i) and section 40(a)(ia) do not apply to depreciation claimed under section 32 on software expenditure that was capitalised. The Tribunal applied the High Court's reasoning that those disallowance provisions target revenue outgoings on which tax was deductible at source, whereas depreciation is a statutory allowance on an eligible asset and is not itself an expenditure outgoing. Because only depreciation was claimed on the capitalised software cost, no disallowance under section 40(a)(i) or section 40(a)(ia) was attracted, and the assessee succeeded. Case-Laws Income Tax Thu, 05 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=308195