Purchase of application Software is revenue expenditure

Issue: Whether expenditure on acquisition of software was revenue or capital expenditure?

Sections Involved:  Section 37 (1) of the Income Tax Act (Capital expenditure is not allowed as per this section)

Appeal by Assessee before ITAT: (Relevant Extract)*

“1. That the Order dated March 23, 2007 passed by the learned Commissioner of Income Tax (Appeals)-XV [“CIT(A)”] is erroneous and bad in law in so

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