Depreciation on Software cannot be disallowed by invoking section 40(a)(i)(a)

UKN Properties Pvt. Ltd. Vs DCIT (ITAT Banglore)  Since the transactions of purchase of software has been completed prior to rendering of decision by Hon’ble Karnataka High Court and since there were decisions which have held that TDS is not required to be made out of payment made for software purchases, following the above said decision we hold that the TDS liability cannot be fastened upon the assessee retrospectively and accordingly disallowance u/s 40(a)(i) is not called for even if the software purchases is treated as revenue expenditure. Accordingly, we are of the view that there is n...