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TMI Blog2022 (11) TMI 554X X X X Extracts X X X X X X X X Extracts X X X X ..... . The assessee is engaged in the process of providing automation, software and hardware engineering. The said expenditure is in the regular course of business of the assessee, which has been named as Software Development Expenditure. CIT(A) has given a categoric finding that the said expenses are not towards Software Development for use by the assessee but for rendering services to the clients ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al Center, Delhi [ in short the CIT(A) ]dated 09/05/2022 for the assessment year 2017-18. 2. The solitary issue agitated by the Revenue in appeal is against findings of the CIT(A) in holding Software Development Expenditure as revenue in nature. 3. Shri Anuj Kisnadwala appearing on behalf of the assessee submitted that the assessee is engaged in the business of process automation software ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (A) reversed the findings of Assessing Officer and held the expenditure to be on revenue account. The ld.Authorized Representative of the assessee supporting the findings of CIT(A) submitted that the Assessing Officer has erred in assuming that the Software Development expenditure is towards development of software for self use of the assessee, whereas, the aforesaid expenditure was towards develo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... velopment for use by the assessee but for rendering services to the clients including overseas clients. Thus, the expenditure has been incurred in the regular course of business of the assessee and for earning revenue and profits, hence, the expenditure is on revenue account. The ld.Departmental Representative has not been able to controvert the findings of the CIT(A). We find no infirmity in the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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