Client Acquisition and HR Costs Deemed Revenue Expenditures u/s 37, Not Capital; Amortization Over Five Years Allowed.

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....Revenue expenditure or capital expenditure - Allowability of expenses on acquisition of clientele and technical human resource i.e., employees to execute the contract - it is not emerging that the assessee has acquired either complete business i.e., the profit apparatus or any capital asset. In such case, the expenses incurred are to be allowed as revenue and assessee has only amortized these expenses in 5 years and the same are allowable as revenue expenditure u/s.37 of the Act. - AT....