Held that whether the assessee had carried on  software development activity, either with the same client or any other client, in subsequent assessment years had to be seen. If the assessee had continued with such business activity in subsequent years, the assessee’s claim could be accepted. The assessee’s claim to deduction towards expenses, depreciation and set off of brought forward loss and unabsorbed depreciation would ultimately depend upon the outcome of the issue whether or not the assessee had carried out any business activity. Matter remanded to the Commissioner (Appeals). (AY 2006-07)