means; (ii) providing technical services outside India in connection with the development or production of computer software, there shall, in accordance with and subject ... profits and gains derived from on site development of computer software (including services for development of software) outside India shall be deemed
this
21
Agreement means and includes services towards software
development, software support, software project management
services, development of new application, maintenance or upgrading
or rework ... level figures contain revenue from both software
services and software products, as against the assessee only providing
software services, we are disinclined to treat this company
ambit of
software development services. Whereas the said comparable is engaged into IT
services, engineering design services and health care services as per their annual ... services to the customers. It is also
involved in providing software development and software services to the clients and
also penetrates IT enabled services (ITES
Digital Consulting are considered as
software development activities of FCS Software Solutions Ltd., the
remaining activities of FCS Software Solutions Ltd. which ... management services, which constitute 11% and 15%
respectively of the total income, are IT enabled services and not linked to the
software development services
both the provision of software services and sale of
software services. On the other hand assessee is engaged in Software
development services where the segmental ... that the said concern Indium Software (India) Ltd. to be not
comparable to the concern engaged in software development services.
26. On perusal of record
this company
viz., (i) software development segment, and (ii) software product
segment. The Assessee is a pure software services provider and not a
software product ... Consulting Services', consisting of Web
Strategy Services, I T design services and in Technology Consulting
Services including product development consulting services. These
services
Consulting Services', consisting of Web Strategy Services,
I T design services and in Technology Consulting Services including
product development consulting services. These services ... into software
development services, this company i.e. e-Zest Solutions Ltd., is
rendering product development services and high end technical services
which come under
engaged in the business
of rendering software development services. The Assessee renders services to Anshin
Software Corporation, USA incorporated as a company under the laws ... shared shows that Inteq Software Limited is not purely software
development service company and provides besides software development, consultancy
services, data warehousing, EDI services besides
assessee as
it is into software products whereas the assessee only provides software
development services to its AEs. The TPO rejected the assessee ... solutions, software consultancy and
design & development of software using latest technology and Bodhtree
is a specialist entity offering niche IT services in software engineering
software research and development
services carries out R&D services for its AE for the development
of software products to its CDS utilizing ... this company is into development of
software products, which cannot be compared with the assessee's
software development services. The DRP and TPO have
