Assessee claimed expenditure incurred for purchase of software as revenue expenditure. Assessing Officer held  that assessee had not started any effort to earn income and it was just in process of making a brand for future utilization and when there was no income chargeable under section 28, no expenses under sections 30 to 37 could be claimed in this regard and noted that assessee had not earned any revenue from its business and treated expenditure as capital expenditure. Tribunal relying upon its order passed in assessee’s own case for previous assessment year reversed view taken by Assessing Officer and allowed claim.  High Court  held that proposition put forth by Assessing Officer that when there was no income chargeable under section 28, no expenses could be claimed by an assessee under sections 30 to 37 was completely unsustainable and since issue that revenue sought to raise before Court was very same issue which Tribunal grappled with in previous assessment year, no substantial question of law arose for consideration.  SLP filed by revenue is dismissed. (AY. 2013-14,  2014-15)