rendering technical services outside India in
connection with production of said software.
Therefore the expenditure incurred in foreign
exchange in providing such technical services outside ... India of computer software and its transmission to
places from India outside India. Before a computer
software is exported, the Software Engineers of the
assessee
rendering technical
services outside India in connection with production of
said software. Therefore the expenditure incurred in
foreign exchange in providing such technical services
outside ... India of computer software and its transmission to
places from India outside India. Before a computer
software is exported, the Software Engineers of the
assessee
rendering technical services outside India in connection with
production of said software. Therefore the expenditure
incurred in foreign exchange in providing such technical
services outside ... India of computer
software and its transmission to places from India outside
India. Before a computer software is exported, the Software
Engineers of the assessee
Mohali, Chandigarh. It provides technical services outside
India in connection with the development and production of computer
software in respect thereto. The return of income ... from the
business of export out of India of computer software for providing all
technical services outside India in connection with development or
production
Mohali, Chandigarh. It provides technical services outside India in
connection with the development and production of computer software in
respect thereto. During the year under ... from the business of export out of India of computer software
for providing all technical services outside India in connection with
development or production
services, sales and marketing
services, regulatory affairs and quality assurance services and
finance and accounting services pre dominantly involves make
available of technical knowledge ... Indian company for included services ?
Analysis:
The fees are for included services. The services are technical,
and the technical knowledge is made available
software development
services. Software development services segment further constitutes three
major sub- segments viz. embedded product design, industrial design and
visual computing labs whereas taxpayer ... generated technical know-how and acquired intangibles computer software
which certainly gives edge to Tata Elexi over other players operating in
software development services provisions
services. That being the position, we opine that the
payment in lieu of freight and logistics services cannot be ranked
as consultancy services ... definition of "fees for
technical services" taken note of by the ld. CIT(A) is "technical
services". He observed that
services,
technical knowledge, experience, skill, know-how, or processes, or
consist of the development and transfer of a technical plant or
technical design to such ... Everest Global Inc. vs DDIT
11
3. Computer software development.
Under paragraph 4(b), technical and consultancy services could
make technology available in a variety
follows:
"Typical categories of services that generally involve either the
development and transfer of technical plants or technical designs, or
making technology available ... mechanical,
metallurgical, and industrial engineering) ;
2. Architectural services ; and
3. Computer software development.
Under paragraph 4{b), technical and consultancy services could make technology
available
