Depreciation Claim Denied: Assessee Fails to Prove Software Ownership u/s 32 of Income Tax Act.

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....TP Adjustment - Claim of depreciation on software - no ownership claim of the assessee proved - Section 32 of the Act provides depreciation on the eligible assets owned wholly or partly by the assessee and used for the business or profession. Hence, the law is clear. There is no ambiguity under the law. Without proper sale, the assessee could not have owned wholly and partly the assets on which depreciation have been claimed - AT....