PCIT v. Adadyn Technologies Pvt. Ltd. (2024)465 ITR 353 /162 taxmann.com 666 (Karn)(HC) Editorial: SLP of Revenue is dismissed, PCIT v. Adadyn Technologies Pvt. Ltd. (2024)465 ITR 409/162 taxmann.com 667 (SC)

S. 37(1) : Business expenditure-Capital or revenue-Software Development expenses-Product abandoned on becoming obsolete due to development in technology-No enduring benefit-Allowable as revenue expenditure.[S. 260A]

Dismissing the appeals of the Revenue the Court held that the assessee’s investment to develop a software platform for desktops had become obsolete due to rapid change in the technology and the assessee had abandoned further development as a result of which it had abandoned the product and incurred a loss. The project having been abandoned, the assessee would not get any enduring benefit. The Tribunal, on a correct analysis of the facts, had held that the expenditure was revenue and not capital in nature. There was no ground to interfere with the findings recorded by the Tribunal. (AY.2015-16, 2016-17)