https://www.taxtmi.com/caselaws?id=790035 ERP and software expenditure was tested on functional character: routine business-facilitating items were treated as revenue, while perpetual licences, capacity enhancement and enterprise-level upgrades creating enduring system benefits were capital, with depreciation allowed on the capital portion. On section 14A read with Rule 8D, no proportionate interest disallowance survived where own interest-free funds substantially exceeded investments, and administrative disallowance was to be recomputed by reference to investments yielding exempt income. The section 14A adjustment was also not added to book profit under section 115JB on the facts. Debenture Redemption Reserve, created by transfer from profits to meet a definite debenture redemption obligation, was not a reserve for MAT adjustment and was not added back to book profit. en-us Tue, 13 Jan 2026 00:00:00 +0530 Sat, 18 Apr 2026 08:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790035 ERP and software expenditure was tested on functional character: routine business-facilitating items were treated as revenue, while perpetual licences, capacity enhancement and enterprise-level upgrades creating enduring system benefits were capital, with depreciation allowed on the capital portion. On section 14A read with Rule 8D, no proportionate interest disallowance survived where own interest-free funds substantially exceeded investments, and administrative disallowance was to be recomputed by reference to investments yielding exempt income. The section 14A adjustment was also not added to book profit under section 115JB on the facts. Debenture Redemption Reserve, created by transfer from profits to meet a definite debenture redemption obligation, was not a reserve for MAT adjustment and was not added back to book profit. Case-Laws Income Tax Tue, 13 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790035