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ITA.No.919/Del./2013 M/s. WNS Business
Consulting Services Pvt. Ltd., Mumbai.
Copy of the STPI approvals/registration
certificate.
Copy of Form No. 56F duly certifying the claim
of deduction under section 10A of the Act.
Details of export proceeds along with its
realization date as per the FIRCs.
Copy of FIRC's.
Summary of invoices and copy of the form
SOFTEX submitted to the STPI authorities along
with the invoices raised during the financial
year 2005-06.
Invoices raised subsequent t the name change
of the company
From the perusal of the above details/documents, my
observations are as follows :
The appellant is engaged in the business of export of
IT enabled BPO services and IT enabled delivery
ITA.No.919/Del./2013 M/s. WNS Business
Consulting Services Pvt. Ltd., Mumbai.
solutions including back-office operations and data
processing services to customers in the financial
services industry in the United States of America.
These services are provided by the appellant
through its customer services undertaking
located in Gurgaon which is registered with the
STPI. The appellant has obtained necessary
approvals/registrations from the STPI.
The activities of business of export of IT enabled
BPO services and delivery solutions to
customers outside India squarely fall within the
meaning of term 'Computer Software' as
clarified by the CBDT in its Notification.
Copy of invoices/shipping bills and Form
SOFTEX along with the invoices raised which
clearly shows that the appellant has exported
the software services through data
communication link provided by VSNL.
7. In so far as the actual rendering of the service is
concerned the Transfer Pricing Officer in his order dated
15/10/2009 in respect of the assessment year 2006-07
categorically recorded that the assessee has provided
these services to the parent company. Further vide
Paragraph No.5.8 the Ld. CIT (A) observed that the
assessee drew his attention to the summary of invoices
and copy of the SOFTEX forms submitted to the STPI
Authorities along with a copy of invoices raised during FY
2005-06 and these documents were also submitted during
ITA.No.919/Del./2013 M/s. WNS Business
Consulting Services Pvt. Ltd., Mumbai.