2022 (11) TMI 554

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....ondent : Shri Anuj Kisnadwala ORDER PER VIKAS AWASTHY, JM: This appeal by the Revenue is directed against the order of Commissioner of Income Tax (Appeals), National Faceless Appeal 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 Develop....

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.... the expenditure on Software Development, is regular business expenditure and has been incurred for Development of Software for use of clients including export to overseas clients. The CIT(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 Of....

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....ar course of business of the assessee, which has been named as Software Development Expenditure. The 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 including overseas clients. Thus, the expenditure has been incurred in the regular course of business of the assessee and for earning re....