2002 (11) TMI 777

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....law, 2. Admit. 3. The following questions of law are framed for adjudication : "(1) Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in directing the AO to recompute the assessed's income by adopting the changed method of accounting ? (2) Whether, on the facts and circumstances of the case, the Tribunal was right in law in holdin....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....we are in agreement with the Tribunal that the same is in the nature of revenue expenditure. It is pertinent to note that the AO, while granting depreciation @ 33.33 per cent on the software, had himself observed that the life of the software was three years. The percentage of such allowance had been fixed by the AO on his own. In our opinion no substantial question of law arises from this issue a....