operations of the appellant are also
included under the definition of IT/ITeS under the IT/ITeS policy of the
State of Maharashtra. Under ... categorization and the categorization was made
by adopting the definition of IT/ITES stated in the said policy. Since then
Industrial Tariff has been applied
company M/s. Acropetal
Technologies Limited, without appreciating that the definition of ITeS
service in the CBDT Notification doesn't differentiate between ... company M/s. E-Clerx
Services Limited, without appreciating that the definition of ITeS service in
the CBDT Notification doesn't differentiate between
contended that the subject property being used for IT/ITeS will fall under
the definition of ‗industrial building' and not under the definition ... respondent-assessee and came to the
conclusion that IT/ITeS would fall within the definition of ‗Industrial
Building' and therefore, the appeals were allowed
company's services fall in the definition of ITeS, there is no reason to exclude
the same on the basis that they ... contention of the TPO that once the company falls
within the definition of ITeS, then there is no reason to exclude the same
also submitted that this
company does not satisfy the definition of ITES as contained in
Rule IOTA(e) of the Rules. Since use of information ... also submitted that this company
does not satisfy the definition of ITES as contained in
Rule IOTA(e) of the Rules. Since use of information
nature of ITES. The Assessee pointed
out that as per the safe harbor rules introduced by the
CBDT ITES has been defined as business process ... also submitted that
this company does not satisfy the definition of ITES as
contained in Rule 10TA(e ) of the Rules. Since use of
information
Business Process Outsourcing (BPO) services fall within the broad
definition of ITES, companies engaged in KPO services cannot be used as
comparables
ITES. The ld AR also submitted that even
if the services rendered are considered to be ITES, the services that are
being classified as ITES ... perused the material on
record. We will look at the definition of ITES as defined in Rule
10TA(e) of the Income-tax Rules
company is engaged in development of software products, whereas assessee
is doing ITES services which in our opinion cannot be compared with
software development company ... observed that the services rendered by this
company fall in the definition of ITES.
14.2.2 We have considered the submissions of the learned counsel
nature of ITES. The Assessee pointed out that as per the
safe harbour rules introduced by the CBDT ITES has been
defined as business process ... also submitted that this company does not satisfy the
definition of ITES as contained in Rule IOTA(e) of the Rules.
Since use of information