Software licence payments and year-end provisions: Tribunal treats use-right fees as revenue and rejects double disallowance.

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....Software licence, database support and related IT expenditure was held to be revenue in nature because it secured only a limited right to use software, with no acquisition of proprietary or copyright rights and no independent enduring asset. Applying the principle from Engineering Analysis, the Tribunal treated the payments as facilitating day-to-day business operations and upheld deletion of the disallowance. On year-end provisions, the Tribunal held that repeated disallowance of the same item would create impermissible double disallowance; the matter was restored for limited verification of prior disallowance or tax deduction and corresponding relief to prevent duplication.....