convenience.
2. The assessee is engaged in the business of providing software
development services and marketing support services to its Associated
Enterprises (AE). The services ... Appellant had any motive of tax
evasion.
GROUNDS RELATING TO TP (SOFTWARE
DEVELOPMENT SEGMENT)
5. The lower authorities have erred in making transfer pricing
adjustment
Income-tax, circle-2(2),
Private Limited (formerly Kolkata.
known as Anshin Software
Private Limited) Vs.
Globsyn Crystals, Tower-1, 6th
floor, Sector V, Salt ... revenue.
13. For that the Authorities below erred in rejecting CG-VAK Software &
Exports Limited from the final set of com parables though
include data,
message, text, images, sound, voice, codes, computer
programmes, software and databases or micro film or
computer generated micro fiche. Section 2(w) defines
devices based on Android. The ACC also requires that any
Android-based software developed OEM's hardware should be compatible.
The Clauses
paras 3.3.6 and 3.3.7
that "Under the software services category, both the onsite and offsite services are
delivered to the customer directly".
Page ... submitted by the Appellant that
Infrastructure Services was akin to software services rendered by the HCL,
Technologies Ltd.
6.2 That on the facts and circumstance
paras 3.3.6 and 3.3.7
that "Under the software services category, both the onsite and offsite services are
delivered to the customer directly".
Page ... submitted by the Appellant that
Infrastructure Services was akin to software services rendered by the HCL,
Technologies Ltd.
6.2 That on the facts and circumstance
paras 3.3.6 and 3.3.7
that "Under the software services category, both the onsite and offsite services are
delivered to the customer directly".
Page ... submitted by the Appellant that
Infrastructure Services was akin to software services rendered by the HCL,
Technologies Ltd.
6.2 That on the facts and circumstance
paras 3.3.6 and 3.3.7
that "Under the software services category, both the onsite and offsite services are
delivered to the customer directly".
Page ... submitted by the Appellant that
Infrastructure Services was akin to software services rendered by the HCL,
Technologies Ltd.
6.2 That on the facts and circumstance
paras 3.3.6 and 3.3.7
that "Under the software services category, both the onsite and offsite services are
delivered to the customer directly".
Page ... submitted by the Appellant that
Infrastructure Services was akin to software services rendered by the HCL,
Technologies Ltd.
6.2 That on the facts and circumstance
paras 3.3.6 and 3.3.7
that "Under the software services category, both the onsite and offsite services are
delivered to the customer directly".
Page ... submitted by the Appellant that
Infrastructure Services was akin to software services rendered by the HCL,
Technologies Ltd.
6.2 That on the facts and circumstance
