The assessee was a public limited company engaged in the business of manufacture and sale of Turbine, Gear and Gear Boxes, sugar plants, water treatment plants, mini hydel power projects, etc. The assessee had, during the relevant previous year, inter alia, incurred an expenditure aggregating to Rs. 1,16,60,400 on implementation of new ERP package which was treated as deferred revenue expenditure in the books of accounts. Though in the books of account, the expenses were treated as deferred revenue expenditure, the said expenses, being revenue in nature, were claimed as deduction in the return of income. The Assessing Officer disallowed the said expenses holding the same to be capital expenditure on the ground that it resulted an enduring benefit to the assessee and allowed depreciation @ 60% on the same. The Tribunal noted that no ownership of any software was acquired by the assessee as a consequence of the ERP expenditure. The assessee had only limited right to use the concerned software product which the assessee acquired without acquiring the right of transferring the said software. Thus, no benefit of an enduring nature had been derived by the assessee as result of said expenditure and the said expenditure was incurred only for smooth working and for improving the functioning of the organization. The Tribunal thus allowed the expenditure. (ITA Nos. 1955 to 1959/Del/2016; dt. 06-08-2020) (AY .2001-02 to 2005-06)