The Chennai Income Tax Appellate Tribunal ( ITAT ) has recently held that 60 percent depreciation would not be allowed on robotix kits.
Assessee Robotix Learning Solutions P. Ltd filing the return claiming 60 percent depreciation on Robotics kits. But the rate was reduced to 15 percent by the Assessing Officer in the Assessment Order. Against this assessment order the assessor filed an appeal before the ITAT.
S. Sridhar, Counsel for the assessee submits that robotix kit is a part and parcel of the computer and therefore, the assessee is eligible for claiming 60 percent depreciation.
D. Hema Bhupal, counsel for the revenue, supported the orders of authorities below.
After considering the contentions of the both side the division bench of the ITAT comprising V. Durga Rao, (Judicial Member) and Manjunatha, (Accountant Member) denied the claim of assessee for depreciation on robotics kits and observed that,
“Computer or software attached is used for operation of robotic kits and therefore, it cannot be construed as if the Robotix kits itself is a computer.”
Further the bench determined that, computer or software attached was used for operation of robotic kits. Therefore, it cannot be construed as if the Robotix kit itself is a computer. Computers are totally different which comprises processing data and not the machinery which undertakes work as per the instruction given through the computer. Therefore, the computer is a different one and robotics kits are entirely different machines.
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