Held that expenses incurred towards replacement of spares in machineries would be allowable as revenue expenditure. Similarly expenses on upgradtion of software for facilitating trading operation leaving fixes untouched is allowable as revenue expenditure. Followed, CIT v. N.J. India Invest (P.) Ltd. [2013] 215 Taxman 78 (Guj.) (HC). (AY. 2005-06)
PCIT v. Gujarat Industries Power Co. Ltd. (2023) 295 Taxman 345 (Guj.)(HC)
S. 37(1) : Business expenditure-Capital or revenue-Replacement of spares in machineries-Up gradation of software-Revenue expenditure.