articles or things or computer
software outside India or expenses, if any, incurred in foreign
exchange in providing the technical services outside India ... previous year, it was engaged in
development of computer software and not in rendering any technical
services. Communication expenses were incurred not for export
expenses incurred
in foreign currency attributable to delivery of computer software for providing
technical services outside India to be excluded both from export turnover ... deductions on freight,
telecommunication and insurance attributable to the delivery of
computer software under Section10A of the IT Act are allowed
only in Export Turnover
computer software and providing technical services in
connection with development of software are distinguishable from each other, the
profits for providing technical services abroad ... only in
respect of profit from export of computer software and profit from rendering of
technical services is not included therein;
(iii) expenses incurred
articles or things or computer
software outside India or expenses, if any, incurred in foreign
exchange in providing the technical services outside India ... previous year, it was engaged in
development of computer software and not in rendering any technical
services. Communication expenses were incurred not for export
articles or things or computer software outside India or
expenses, if any, incurred in foreign exchange in providing the
technical services outside India ... previous year, it was
engaged in development of computer software and not in rendering any
technical services. Communication expenses were incurred not for export
international transactions pertaining to provision of contract
software development ("CSD") services and technical support
services ("TSS") by the Appellant ... learned TPO
computed adjustment of Rs.57,34,68,890/-to the software
development services segment.
4.3 Under the Technical Support Service (TSS) segment
Classic Linen International Pvt Ltd., ... vs Dcit Corporate Circle 1(2), Chennai on 11 December
account of arms
length price computed for software design and development
service segment being technical support services provided by
assessee ... Technical assistance and clarifications
We understand that APCC US provides technical assistance,
information and certain technical clarifications in the provision
of technical support services provided
The Acit, Circle-2(1)(1),, Ahmedabad vs Indo Colchem Pvt. Ltd.,, Ahmedabad on 30
appreciating the evidences furnished by the Appellant to demonstrate
that the services were actually rendered and holding that no service
was rendered ... engaged in the
business of providing engineering, software and technical design services with
use of Computer Aided Design (CAD), Computer Aided Manufacturing (CAM),
advanced pressure
