technical services' include development of software, testing of
software, domestication of software and since the assessee is engaged
in developing and providing software ... involve technical services and is part and parcel of rendering
services; no software development is possible without technical
services; software development and technical services
engaged in the
business of development and export of computer softwares and
rendering technical services.
(b) The Respondent has shown gross income from business ... generic software and
providing customized software development services for
domestic as well as for foreign clients through its two units
situated in Software Technology Park
integration, consulting etc; ID services include global on-
site/offshore software development, custom software development/bespoke
software development, independent software testing, RIA/Ajax application
development ... services are not comparable to
software development services and therefore companies rendering KPO
services ought not to be considered as comparable to software development
companies
into data
analytical services; operation management services;
accounts reconciliation services which are aimed at
reducing process errors and operational risks and that ... Citigroup to its corporate and retail
clients. Technical services involve software testing,
verification and validation of software at the time of
implementation and data centre
facts, even the payments for the warranty services and
support services, can be treated as fees for technical services in
view of provisions of paragraph ... rendering of
any technical or consultancy services (including through he provision of services
of technical or other personnel) if such services:
(a).....................
(b) make available
things or computer
software outside India or the expenses, if any, incurred in foreign
exchange in providing the technical services outside India ... things or computer software outside India, or expenses if
any incurred in foreign exchange, in providing the technical services
outside India should not be included
technical services in the category of KPO Services and therefore cannot be considered as
comparable to an assessee rendering purely software development services. The relevant ... into software development services, this
company i.e. e-Zest Solutions Ltd., is rendering product development services and high end
technical services which come under
Citigroup
to its corporate and retail clients. Technical services
involve software testing, verification and validation of
software at the time of implementation and data centre ... Technical services' involve software testing,
verification and validation of software item,
implementation and data centre management activities.
The `Technical services' rendered by this
that, assessee is engaged in
development and export ofcomputer software and not in providing
technical services outside India.Assessee submitted copies of Audit
Report under ... nothing but theexpenses incurred
overseas for providing the software developmentservices
which are technical services. Be it as it may, these are
theexpenses incurred in foreign
Assessee
is engaged in the business of providing contract software development services
and related services to its Associated Enterprises ('AE' for short ... year, it was engaged in development of computer
software and not in rendering any technical services. Communication expenses
and travel expenses were incurred
