Enduring benefit test cannot be applied mechanically on software expenses

Brief of the case:

• The Hon’ble Kolkata High court in the case of Indian Aluminum Company Ltd. held that application software is an aid in the business operations rather than the tool itself. Therefore, the payment for such application software, though there is an enduring benefit, does not result in acquisition of any capital asset and it merely enhances the productivity or efficiency and hence, has to be treated as revenue expenditure.
• Therefore, the test of enduring benefit cannot be app

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