Expenditure on acquiring master copy of software subject to obsolescence is allowable as revenue expenditure

Merely because expenditure has been incurred for material for duplication without acquisition of proprietary and when the expenditure is not of capital nature, the said Section would not be applicable.

In any case, the said provision is not applicable with effect from the 1^st day of April, 1998. The view we have taken finds affirmation and support from the decision of the Delhi High Court in Denso India Limited (supra). It supports the case of the appellant as it has been held that depreciation claim in respect of intangible

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