Assessee, it had made those payments for the purchase of
software and it was asserted that the Assessee is a Value Added Reseller ... software in question. The Revenue on the other hand contends
that the payments made by the Assessee were in the nature of royalty and,
therefore
ITAT erred in holding that receipts of the assessee from
sale of software is not taxable as royalty under the India -UK
DTAA?
2.2 Whether ... appreciating that receipts by
the assessee is ultimately due to use of software by end users and
end users use the software only as licensee
respect of the ADIPL's software development
segment.
6. In view of the said order of the TPO, the AO passed a draft
assessment ... proposing an enhancement of
₹57,29,49,678/- in respect of the software development segment of
ALTIPL.
8. The AO passed a draft assessment order
respect of the ADIPL's software development
segment.
6. In view of the said order of the TPO, the AO passed a draft
assessment ... proposing an enhancement of
₹57,29,49,678/- in respect of the software development segment of
ALTIPL.
8. The AO passed a draft assessment order
liable to
be granted as the invention is mainly performed using software. In the said
affidavit, it is also highlighted that the computing environment ... which can be either
removable or non-removable, contains instructions for the software [4780],
which employs a 4x4 pre/post-filtering method integral
allotment order:
14.
The supplier Is required té provide Hardware and Software up-gradation from time to'tme, at mutually
agreed terms & conditions ... Duting warranty period all Software updated version(s)/up-gradation are
expected to be provided at free of cost.to SKIMS Soura. Further, any shortcomings
abroad related to niche technical services
to implement and run the software at the client's
premises and location. The plaintiff company provides
software ... cycle management
i.e., built and developed using the components of a
software technology platform called enterprises
resource planning. The plaintiff company
world. The officers of the
department and vendors developing the department software
were also not untouched. I say and submit that assessment
through Faceless scheme ... premature phase, which had its own technical
problems & issues and software was being updated
constantly. I humbly say and submit that as any other
through its representative had approached the
plaintiff to purchase ERP software and licenses of some softwares
and to procure services in support ... facility to purge all the transactional data in
the microsoft dynamic ERP software by making initial payment of
Rs. 1,03,250/- including taxes
once
implemented, will improve the rates further. The overall systems
– network and software – have shown to meet desired
requirements in real life condition. Finally
