If the expenses are of revenue nature, then the same are to be allowed and section 35D will not be applicable

RELEVANT PARAGRAPH 4.1 The Assessing Officer from the details filed noticed that the assessee has claimed a sum of Rs. 3,24,91,003/- as deferred revenue expenditure. The assessee vide letter dated 15th December, 2005 submitted that a new call center was in the process of being completed, but was not completed during the year. The expenditures is revenue in nature and therefore, this has been claimed in the current year. According to the Assessing Officer, setting up of call center is a new business of the assessee. The expenses are in the nature of preliminary expenses and are required to be c...