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2022 (7) TMI 32 - AT - Income TaxRevenue expenditure or capital expenditure - Allowability of expenses on acquisition of clientele and technical human resource i.e., employees to execute the contract - assessee has claimed 1/5th on account of amortization of business acquisition expenses - HELD THAT:- DR could not controvert the fact situation that the assessee has practically acquired business contracts of these three US companies with their clients for software development along with the technical resources including employees to execute contracts. We noted that from the facts, it is not emerging that the assessee has acquired either complete business i.e., the profit apparatus or any capital asset. In such case, the expenses incurred are to be allowed as revenue and assessee has only amortized these expenses in 5 years and the same are allowable as revenue expenditure u/s.37 of the Act. We find no infirmity in the order of CIT(A) and hence, the appeal of Revenue is dismissed.
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