It has been held in the case of Kas Movie makers that for clamining dedcution under section 80HHF owner ship in the software is sine qua non. In this case the CIT(A) has allowed the appeal of the assessee and the ITAT Bench has decided the issue in the favour of revenue. On appeal the High Court has affirmed the order of the ITAT passed by Mr C.L.Sethi Hon'ble Member of the ITAT. If any body required judgment then please mail me i will send the PDF file