Held that the period of licence could not be the basis to decide whether the expenditure was capital or revenue expenditure. The test to be applied was whether the expenditure was incurred to facilitate the conduct of business more efficiently in its operation and not in the capital field. The assessee rendered software development services and therefore the use of the software was in its operations and not in the capital field and in that view of the matter, the expenditure in question deserved to be allowed in full. (AY. 2014-15)
Altisource Business Solutions Pvt. Ltd. v. ITO (2022) 99 ITR 647 (Bang) (Trib)
S. 37(1) : Business expenditure-Capital or Revenue Expenditure-Payment for acquisition of application software-Revenue expenditure.