Assessee is  engaged in business of registrar and transfer agent as licensed by SEBI.  It was handling large volume of market sensitive data and information which was available through general customized application software for which assessee acquired software licenses.  The payment made was capitailsed in the books of account and claimed depreciation at 60%.AO allowed the depreciation at 25% which was confirmed by CIT(A). Tribunal allowed the depreciation at 60%. On appeal by the revenue the Court held that   The Supreme Court in Bimetal Bearings Ltd. v. State of Tamil Nadu [1991] 80 STC 167 had pointed out that the ‘entry’ to be interpreted is in a taxing statute; full effect should be given to all words used therein and if a particular article would fall within a description, by the force of words used, it is impermissible to ignore the description, and denote the article under another entry by a process of reasoning. It was further held that by applying the rule of interpretation, the relevant entry under old appendix I Clause III(5) states that computers including computer software and the Notes under the Appendix defines ‘computer software’ in clause 7 to mean any computer program recorded on disc, tape, perforated media or other information storage device. Noteworthy to mention that the notes contained in the appendix, the term ‘computer’ has not been defined. If a particular article would fall within the description by the force of words used, it is impermissible to ignore the word description. Thus, going by the usage of the equipment purchased by the petitioner, a decision is to be taken.  Accordingly up held the order of the Tribunal. Followed CIT v. Cactus Imaging India (P) Ltd. (2018) 406 ITR 406 (Mad.) (HC)  (AY. 2012-13, 2014-15 )