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7.1 The assessee being aggrieved is in appeal before us.

7.2 The learned AR made the following written submissions:-

"6.3 In the present case, expenses were incurred for the use of software for a limited period. The appellant did not secure the source code. It was prevented from modifying or duplicating the software. It could not decompile or disassemble the software. No derivative works could be created. The appellant was permitted to use the software for its business, in a limited manner. No 'copyright' right was secured by the appellant in relation to use of software. The impugned expenditure did not result in acquisition of any asset by the appellant. The software expenses were incurred for carrying day to day activities.