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). Allocation of corporate overheads to units claiming deduction under section 10A/ 10AA/ 10B- Held, since deduction is allowed u/s 10A/10AA/10B of the Act on the profits derived fr...