11.With regard to the license fee, which was for
acquiring a software license of shelf life of less than two
years was held to be as allowable as revenue expenditure in CIT
Vs. Toyota Kirloskar Motors (P.) Ltd. reported in [2013] 30
Taxmann.com 294 (Karnataka). In CIT, Bangalore Vs. Robert Bosh
India Ltd. reported in [2014] 50 Taxmann.com 275 (Karnataka),
the amount paid by the assessee for purchase of software was
held to be revenue expenditure even when the same was used in
course of business of assessee not only during the assessment
year under consideration, but also during the subsequent year.
In Oriental Bank of Commerce Vs. Additional CIT reported in
[2018] 93 Taxmann.com 432 (Delhi), the expenditure incurred by
the assessee on acquiring license to use software which did not
confer any enduring benefit on assessee was allowed as a
deduction under Section 37(1) of the Act, wherein the decision
of the Hon'ble Supreme Court in Alembic Chemicals Works Co. Ltd
Vs. CIT reported in 177 ITR 377 (SC) was followed. In CIT,
Trichy Vs. Lakshmi Vilas Bank Ltd. reported in [2018] 97
Taxmann.com 105 (Madras), expenditure incurred by the assessee
towards software expenses was treated as revenue expenditure as
advantage, though endured for an indefinite period, it merely
facilitated assessee's trading operation, enabling it to carry
on business more efficiently. In the said case, the contentions
of the assessee that the software was a pre-designed software
