include development of software, testing of software,
domestication of software and since the assessee is engaged
in developing and providing software to meet the need ... that software is 'goods' and involve technical services
and is part and parcel of rendering services; no software
development is possible without technical
include development of software, testing of
software, domestication of software and since the assessee is engaged
in developing and providing software to meet the need ... that software is 'goods'
and involve technical services and is part and parcel of rendering
services; no software development is possible without technical
pointed out that the earnings in foreign currency were only from
software development services and products other than exports and that
there was no other
Multinational Company based in India
engaged in the business of software development services globally. For the
assessment year under consideration [AY 2011-12], the assessee ... TNMM) at vs
subsidiary segment 13.60%
Receipt of software 199,97,48,610
level (External
development services
comparables)
from overseas
subsidiaries
2. Citi Segment Provision
contended that the petitioner company is engaged in providing services related to development of computer software and 100% of such income is eligible for deduction
Royal Info Services Private Limited vs The Recovery Officer on 31 March, 2016
Author: T.S.Sivagnanam
Bench: T.S.Sivagnanam
IN THE HIGH COURT ... respondents.
2. Petitioner is a company, engaged in software development, and other allied services. The petitioner is a defaulter to the respondent-organization, as they
wherein the assessee provided
software services to another STP Unit in Bangalore and the services
were provided on a principal to principal basis and based ... recipient of those services on the
asseessee therein with instructions to bill and deliver to the recipient.
The software development work done by the said
trade mark pentasoft and engaged in software development and export in the line of various software products acquired from PMGL exclusively. Further it took note ... trade mark pentasoft exclusively and also to carry on business and software development export and training by restraining PMGL from carrying out the same activities
reason that it was a giant
Company in the area of development of software.
8. In PCIT Vs. Symphony Marketing Solutions India ... Delhi)], it was held that where assessee was
rendering ITES services to its AE as a captive service provider, a company
12
http://www.judis
called as technical services under
Section 9(1)(vi) of the Act. Since sales and
marketing functions are routine function for
development of business ... standard software
used for tracking sales efforts and the software
is not owned by the parent company. It is a
third party standard software. There
