The assessee had developed digital content which was held by assessee as an asset and was used in various films etc. which could be equated with computer program and claimed depreciation at 60%. AO allowed the depreciation at rate of 25 per cent treating it as intangible. Tribunal held that digital content was manipulated by assessee to be used in different films but still retained character of copyrighted material being intangible assets hence eligible for depreciation at rate of 25 per cent. (AY. 2007-08, 2009-10)
Pentamedia Graphics Ltd. v. DCIT (2020) 80 ITR 555 / 185 ITD 45 / 190 DTR 391 / 205 TTJ 892 (Chennai)(Trib.)
S. 32 : Depreciation-Intangible assets-Digital content, Animation software-Multimedia and entertainment industry-Eligible depreciation at rate of 25 per cent and not 60%.