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

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-SLP of Revenue is dismissed.[Art. 136]

Dismissing the appeals of the Revenue the High 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.  SLP of Revenue is dismissed. (AY.2015-16, 2016-17)