cannot be
included because of functional dissimilarity and distorted segmental account. The
company is engaged in the business of software product, computer programming,
consultancy ... software development services. However, the perusal of the Annual
Report reflect that the software development and services segment reported by the
company, includes income earned
that the profits derived from export of articles
or things or computer software shall be the amount which bears to the profits ... does not include freight,
telecommunication charges or insurance attributable to the delivery of
the articles or things or computer software outside India or expenses
that plaintiff is wholesale dealer of computer components
including its Peripherals & parts and also software to support
services and defendant
software business arrangement for carrying out any software business
relating to development and export of computer software and consultancy
services including design development, maintenance ... ground with respect to
software expenditure for Rs.11.67 Lacs. During assessment proceedings, it
transpired that the assessee purchased software
agreed by the parties that for the purposes
of computation of cost, shall include all cost reasonably
and necessarily incurred by assessee in performance ... between the parties that all
information including specifications, designs, drawings,
results from computer programs and any software that may
be developed during the course
Steria India Ltd., Noida vs Addl.Cit, Speciaql Range-8, New Delhi on 28 September
huge revenues from software
products. It is also seen that the break up of revenue from
software services and software products is not available ... functions under the software development and services
segment namely
(a) Product design services
(b) Innovation design engineering and
(c) visual computing labs
matter for
working out the correct margin in case of Ace software can be set aside
to the file of the TPO for fresh adjudication ... DCIT
Asst.Year - 2007-08
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i. Whether Ace software Exports Ltd. margin computed by the
TPO is correct in the given facts
derived by an undertaking from export of articles or things or computer software is
allowed from the total income of the assessee. Further ... profit included a sum of
Rs.6,99,92,839/- which were not derived from export of article, thing or computer
software. The details
assessee had requested for introduction of two
additional software distribution companies, namely, Unisys Software and Holding
Industries Limited and JMD Ventures Limited for which data ... same should be included. For the above proposition, he
submitted as under:-
Sr.No. Name of Company Business description
1. Unisys Software and Holding
