Sling Media (P.) Ltd. v. DCIT (2022) 194 ITD 1 (Bang.)(Trib.)

S. 32 : Depreciation-Software development service-Machinery installed in office premises-Not manufacturing-Not entitle to addition depreciation. [S. 32(1)(iia)]

Assessee claimed additional depreciation under section 32(1)(iia) on block of assets like Computers and Software.  Assessing Officer disallowed claim of additional depreciation on premise that as per proviso 2B to section 32(1)(iia) any machinery or plant installed in office premises is not eligible for additional depreciation. Commissioner (Appeals) upheld disallowance of additional depreciation holding that assessee was not engaged in manufacturing or production of article or thing and hence was not entitled for additional depreciation. On appeal the Tribunal held that  development activity carried on by assessee could not be considered as manufacturing activity.  (AY. 2016-17)