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7. The fifth disputed issue is with respect to purchase of computer software and software development cost. The A.O found that the assessee has incurred an expenditure of Rs.1,37,60,267/- under computer software and supplies including license to use software. Whereas the asssessee has submitted the information vide letter dated 16.12.2005, the A.O found that out of the above details Rs.1,32,45,017/- has been stated to be on account of off the shelf computer software packages and treated as revenue expenditure. The AO has dealt on the facts and submissions of the assessee and is of the opinion that the claim cannot be fully allowed and observed at Para 7.4 of the order as under: