holding that the revenue
received by the assessee from supply of software is not
taxable in India as Royalty ... appellant is engaged in
the activity of providing mining solutions through software
developed by M/s Datamine Corporate Ltd., UK. The appellant
claimed that
General of Police, was already in the midst of developing
a software, since 2014, for the purpose of registering
FIRs and uploading data and controlling
Jaishri Laxmanrao Patil vs The Chief Minister And Ors. on 5 May, 2021
Equivalent citations
Flipkart Internet Pvt Ltd vs Competition Commission Of India on 23 July, 2021
Bench: Satish
that the search-
based Ads are triggered by a way of automated software
algorithms that match the search query entered by a user with ... advertisements on Google Ads and is simply a free
facility or a software tool that is separately available to the
advertiser and can be used
proprietary Customer Relationship Management (CRM) and Dealer
Management system (DMS) software (in terms of Clause 10(a) and 10(c)
of the Dealership Agreement ... denied imposition of
compulsorily annual maintenance contracts (AMCs) charges, training charges,
SIEBEL software fee, ISO certification charges etc. either on dealers or customers.
58. Further
proprietary Customer Relationship Management (CRM) and Dealer
Management system (DMS) software (in terms of Clause 10(a) and 10(c)
of the Dealership Agreement ... denied imposition of
compulsorily annual maintenance contracts (AMCs) charges, training charges,
SIEBEL software fee, ISO certification charges etc. either on dealers or customers.
58. Further
driver-partners of Uber were not restricted from registering
with other software application services including those of competitors.
Uber submitted before the DG that
transfer price of the
Appellant's international transactions in respect of software
development services. Further, the Learned Commissioner of
Income-tax (Appeals) -III, Bangalore ... with respect to adjustment to the transfer price of the
software development services, the Ld. CIT(A) erred in
upholding the action
transfer price of the
Appellant's international transactions in respect of software
development services. Further, the Learned Commissioner of
Income-tax (Appeals) -III, Bangalore ... with respect to adjustment to the transfer price of the
software development services, the Ld. CIT(A) erred in
upholding the action
