Amortization of expenses

Additions were vacated by the First Appellate Authority on the ground that estimation of life of intangible asset was to be determined by the taxpayer

Taxpayer contended that S.24(3) of the Income Tax Ordinance, 2001 provided the terms "normal useful life in whole years" that was three years in taxpayer's case; that application of ten years came into play where a normal life of an intangible was more than ten years or where the same was not ascertainable; and that in those conditions, it would be restricted to ten years as per S.24(5) of the Income Tax Ordinance, 2001

Validity

Application of 10 years came into play where a normal life of an intangible was more than ten years or where the same was not ascertainable

Life of computer software in the case of taxpayer was only three years which could not be stretched to 10 years

In the present world technological advances were so fast that even before three years such a programme became outdated

Addition made being not maintainable, order of First Appellate Authority was confirmed by the Appellate Tribunal.