expenditure
computed by the TPO was after considering the total turnover of the
said concern including that of the product and projects related ... incurred
only for the software services/embedded services segment, and
secondly, it is wrongly compared with total turnover which included
the turnover of products
Patni Computer,, Pune vs Department Of Income Tax
Author: G.S. Pannu
Bench: G
Including
specifically the introduction of subsection (4) of section 10A which provides
an artificial meaning to profits derived from export of computer software
made
compulsory. The softwares in which the e-returns were filed, there was
no provision for attaching any notes which was otherwise available while
filing ... 2006,
dated 10-10-2006 stated that no enclosures including computation of
income/notes, financial statement etc. should be filed with e-return
lacs is received towards the reimbursement of expenses and included in
the total revenue. As explained to you, the debt notes for
reimbursements are raised ... profit derived by the undertaking from the export of
computer software for which exemption u/s 10A is available. In other words,
exemption
This decision in a sense gave wider meaning to the term
computer software consistent with object of section 80HHE and general
policy ... this earning. The definition of "Computer Software" provided in Section 80HHE of
the Act read with clarification made by the CBDT vide
Aquapharm Chemical Co Ltd, Pune vs Assessee
IN THE INCOME TAX APPELLATE TRIBUNAL
Pune Bench
where assesses
have a bona fide view of how taxes should be computed, the assessee would
have to pay taxes based on the other ... basis of
Form 16 issued by his employer, which did not include reimbursement.
However, on the basis of advice, the assessee's employer paid
Starent Networks India Private ... vs Assessee
Author: G.S. Pannu
Bench: G.S. Pannu
IN
Patni Computers Ltd., Pune vs Assessee
Author: G.S. Pannu
Bench: G.S. Pannu
