Madras HC Quashed Reassessment for Limitation Breach Despite Software Depreciation Dispute

CIT Vs Cognizant Technology Solutions India Pvt Ltd (Madras High Court) The Madras High Court dismissed the Revenue’s appeal challenging the Income Tax Appellate Tribunal’s order which had quashed the reassessment proceedings against the assessee for AY 2002–03 and upheld the claim of depreciation on computer software at 60%. The Revenue raised two substantial questions of law: first, whether the reopening of assessment under Section 147 was valid; and second, whether depreciation on computer software could be allowed at 60% when the specific amendment prescribing that rate was stated to...