TMI Blog2002 (11) TMI 777X X X X Extracts X X X X X X X X Extracts X X X X ..... ng 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 holding that the assessed-firm was entitled to th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hat 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 as well. 5. The appellant shall file wi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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