PCIT v. Trigent Software Ltd. (2023)457 ITR 765 /147 taxmann.com 52 (Bom)(HC)

S. 37(1) : Business expenditure-Capital or revenue-Software company-Expenditure on developing new product-New product abandoned as not feasible-Allowable as revenue expenditure.

Dismissing the appeal of the Revenue the Court  held  that the  expenditure on developing new product and the new product abandoned as not feasible. No new asset came into existence which would be of an enduring benefit to the assessee, and therefore, in these circumstances, the expenditure could only be said to be revenue in nature.(AY.2006-07, 2007-08)