Software Development Company,
having special expertise in emerging technologies such as Cloud computing
business intelligence, etc. Therefore, the same cannot be compared with the
assessee ... Software Development
Company, having special expertise in emerging technologies such as Cloud
computing business intelligence, etc. Although, it is involved in diversified activities
order) software services and software new investments in four thrust
product as enunciated in AS areas: Cloud computing, analytics,
2. Appellant has not submitted ... company
clearly differentiates between OPD
3. Super profit should be and IT services. The skill set and
justified with extraordinary the expertise required
delivering
software-driven cloud networking solutions for large datacentre storage
and computer environments. It also sells its products and services
through distributor channel as well
provision of training services also under the
head 'software services from local unit', 'export of
software services', 'revenue from subscription ... providing services in most advanced and
niche area of technologies such as Robotic Process
Automation, Big Data Analytics& Cloud Computing.
42. From the profile
including software
development services for automotive, communications,
consumer products, health-care and retail. It also provides
animation and Visual Effects (VFX) services for feature films ... specifically focuses on cloud computing,
Big-Data and analytics, enterprise collaboration and
enterprise mobility which are different from the services
provided by the appellant company
diversified
activities, including cloud computing, infrastructure
management, analytics & information management platforms etc.
Whereas, the assessee is simply providing software development
services
That Impugned Order erred in failing to
appreciate that income from cloud services
cannot be taxed as "Royalty" in the hands of
distributor ... conceded before Hon'ble
Delhi High Court that the income from cloud
services is not taxable as royalty.
3.5 That Impugned Order erred
Centre For Public Interest Litigation vs U.O.I.& Ors on 8 April, 2016
Constitution; (17) "online information and database access or retrieval services" means services whose delivery is mediated by information technology over the internet or an electronic ... information technology and includes electronic services such as,- (i) advertising on the internet; (ii) providing cloud services; (iii) provision of e-books, movie, music, software
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 included variety of services such as IT life
cycle, infrastructure management, cloud services, IT application management which
are different from services provided
