kinds of
goods all over the world. Goods thus includes computer
software. Clause 11 of the Incidental objects as set out in
memorandum empowers ... things referred to in
clause (i) of sub-section (2), includes production of computer
programmes...."
"SECTION 10B. SPECIAL PROVISION IN RESPECT
only activity which
qualified for the benefit was "computer software development" and that the
assessee's activity i.e. programme management ... services
rendered or extended by the assessee were not "computer software", is contrary to
the record. The Assessing Officer's order
term "industrial undertaking" in a broad sense, so as to include
processing activity. Viewed from that perspective, the specialized activity of
diagnostics ... find that the
software on the Master Media is application software. It is not
an operating software. It is not system software
engages itself in the promotion and establishing telecom
services and allied activities, including mobile and cellular services. Pursuant to its
main object it leased ... towards software expenses. The assessee claimed the installation
expenses as a deduction, debiting it to the profit and loss account. The software
expenses
Cit vs Rio Tinto India Pvt. Ltd. on 5 October, 2012
Author: S.Ravindra Bhat
