Alembic Chemical Works Co. Ltd vs Commissioner Of Income Tax, Gujarat on 31 March, 1989
Similar decision taken
in KGISL Technologies and Infrastructures Private Limited Vs.
Assistant/Deputy Commissioner of Income Tax, Company Circle-V,
Chennai [decided on 27.11.2018 in TCA Nos.73 to 74 of 2011], wherein
the Court, apart from taking note of decision in Alembic Chemicals Works
Co. Ltd Vs. CIT, noted the decision in CIT Vs. Southern Roadways Ltd
decided on 07.10.2006 in T.C.(A). No. 2454 of 2006 and decided the
substantial questions of law in favour of the assessee by treating the
expenses incurred in developing/upgrading the software to be revenue
expenditure.