Depreciation cannot be disallowed under section 40(a)(ia)

Wipro Limited Vs Addl. CIT (ITAT Bangalore)

Claim of depreciation on software-

Depreciation claimed by the assessee on the amount of software capitalized was disallowed invoking provisions of section 40(a)(ia) for non-deduction of tax at source.

Held, depreciation is a statutory allowance and hence it cannot be considered as expenditure. Accordingly, disallowance of depreciation cannot be made under section 40(a)(ia).

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