purposes of this clause, "royalty" means
consideration (including any lump sum consideration but excluding any
consideration which would be the income ... information
includes and has always included transfer of all or any right for use or right
to use a computer software (including granting
computer
software" means any computer programme recorded on any disc,
tape, perforated media or other information storage device and
includes any such ... 2011
right for use or right to use a computer software (including granting
of a licence) irrespective of the medium through which such right
Depreciation Schedule to IT Rules, 1962.
'Computers including computer software" are eligible for depreciation @
60 %. As per Note ... Delhi), it was held that 'computer
software' is eligible for depreciation @ 60% This decision of the ITAT,
Delhi (SB) in the case
computer
software" means any computer programme recorded on any disc,
tape, perforated media or other information storage device and
includes any such ... 2011
right for use or right to use a computer software (including granting
of a licence) irrespective of the medium through which such right
software including services for development of software, outside India shall be
deemed to be the profits and gains derived from the export of computer ... software including services for the development of such software outside India is
deemed to be the profits and gains derived from the export of computer
copyright of
literary, artistic, scientific or other work (including computer software,
cinematographic films, audio or video tapes or disks, and other means of
image ... totally misled himself
in making the disallowance in the order, including the
computations u/s. 10A . Ld.CIT(A) had correctly came
facts, by upholding the action
of the AO/ TPO in computing the ALP without giving benefit of +/-5 percent
under the proviso to section ... payments made on purchase of computer software and there were many
favorable judicial precedence including the jurisdictional tribunal rulings.
22. Without prejudice
The Dcit, Circle-4,, Ahmedabad vs Gujarat Gas Trading Co. Ltd.,, ... on 21 September, 2017
Astral Pharmaceuticals Industries ,, ... vs The Dy.Cit, Circle-1(2),, Baroda on 21 September, 2017
shall separately execute a Technology and Software license
agreement for the provision of computer equipment and software supplied
by SCS. Contractor shall separately execute ... India shall 'separately execute a technology and software license
agreement' for the provision of computer equipment and software supplied
by the assessee
