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
deputation to foreign customers. The manpower is utilised for rendering services in computer software even in India. In the letter dated 02.12.1997, giving the note ... incentive for promoting export of computers. Thus, any technical service thus rendered in connection with the development of computer software also is taken within
stated to be fro export out of India of
computer software, but for technical services
mentioned in 80HHE(1)(ii) and there would ... 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
assessee
must provide technical services and these services must be
provided in connection with the development of computer
software. The expression 'technical service ... persons sent
abroad being technically qualified, they were rendering technical
service in connection with the development or production of
computer software outside India. Such persons
activity contemplated by the Section
namely export of computer software and rendering of
technical services outside India. The income from services
rendered in India cannot ... engaged
in the export and domestic sale of computer software,
provision of technical services in and outside India and
manufacture and sale of fuel injection
technical services
rendered in post-sale services would stand on a
different footing when compared to pre-sale services. If
any technical service is rendered ... Assessing
Authority to decide whether the said technical services
rendered was in connection with the computer software
business, export of computer software
respect of profits from export of computer software where
the business entity provides technical services outside India in
connection with developments or production of computer ... derived from
37
export of computer software or under the head of 'rendering
technical services outside India' and having a nexus with
export
includes
expenses for software
development, business
development, for
ascertaining customer
requirements, etc. and that
“software development”
will not amount to
“technical services” within
the meaning ... were examined or not, but
made a standalone statement that software development and
technical services are two faces of one coin. We fail to
understand
includes
expenses for software
development, business
development, for
ascertaining customer
requirements, etc. and that
“software development”
will not amount to
“technical services” within ... were examined or not, but
made a standalone statement that software development and
technical services are two faces of one coin. We fail to
understand
Software Software Software Software Software
undertaking Technology Park Technology Technology Technology Technology
Unit-I Park(India Park(India Park Unit-IV Park Technical
Development Engineering ... Computer software of Computer Services
the software and software and and software software and (Technical
undertaking software services software services services software Support)
services
Date
