2020 (4) TMI 518

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....9;) pursuant to the directions given by learned Dispute Resolution Panel (DRP). 2. These appeals were earlier disposed of by the co-ordinate Bench on 12.4.2017. Subsequently, the order passed in the appeal of the assessee was recalled vide Misc. Petition Order dt.5.7.2017 passed in M.P. No.130/Bang/2017 for limited purpose of adjudicating Ground No.5 urged by the assessee, since the said ground was not disposed of in the original order. However, the Registry has erroneously posted the appeal of the revenue also before the Bench along with the appeal of the assessee. Since the appeal filed by the revenue has already been disposed of, the same does not require adjudication again. 3. The Ground NO.5 agitated by the assessee read as under....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... submitted that the assessee had capitalized entire software purchases of Rs. 51.50 lakhs for Income Tax purposes, even though it was treated as revenue expenditure for book purposes. Accordingly while computing the total income the entire amount of Rs. 51.50 lakhs was disallowed by the assessee. Out of the above said purchases, the assessee has not deducted tax at source on software purchases amounting to Rs. 6.24 lakhs. Since entire software purchases have been capitalized for income tax purposes, the assessee claimed depreciation thereon. Though the Assessing Officer has disallowed depreciation under Section 40(a)(ia) of the Act, the DRP deleted the disallowance of depreciation and added back the entire purchase cost of Rs. 6.24 lakhs. T....