Whether when assessee provides software services, expenses incurred on development of software are revenue ?

ACIT Vs M/s Aftek Infosys Limited (ITAT Mumbai)- Whether when assessee provides software services, expenses incurred on development of software are revenue ? 

Assessee’ s business is that of computer software services and products development. In order to supply software to its customers as per their requirements, the assessee has necessarily to incur certain expenses which go in making the product customised. When the sale proceeds are considered as revenue receipt, there is no reason for

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