Depreciation claim disallowance u/s 40(a)(i) for failure to deduct TDS on capitalized software payments...

Depreciation claim disallowance u/s 40(a)(i) for failure to deduct TDS on capitalized software payments is disallowed, following coordinate bench decision. Addition u/s 28(iv) for assets received free of cost from AEs for testing purposes is rejected, as assets are temporary, returned/destroyed after testing, pricing agreed under MAP embeds indirect benefits, and billing is cost-plus basis, precluding separate addition u/s 28(iv). Assessee's grounds allowed, revenue's appeal dismissed. .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X