referred to in the
aforesaid Section is business in computer
software or providing technical services. The
deduction is to the extent of the profits derived ... assessee from such business namely,
computer software export business or technical
services provided in connection therewith. Sub-
Section (3) of Section 80HHE provides
regarded as being
engaged in rendering technical services but in the
development of computer software. The appellant has
relied on the decision in Zylog Systems ... companies was in connection with
supply of computer software or were in connection with rendering technical
services but he replied that no such material
expenses, if any, incurred in foreign
exchange in rendering of services (including computer software) outside
India;
(ii) ................"
18.5 Even though the major part ... there is no need for rendering technical services, but 'rendering of
any services including computer software outside India' is covered as part
comparable to software development services
and therefore companies rendering KPO services ought not to be
considered as comparable to software development companies ... 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
delivery of the computer software outside India
or expenses, if any, incurred in foreign exchange in providing
technical services outside India. Thus statutorily parity ... article or things or
computer software outside India or expenses incurred in foreign
exchange in providing technical services outside India are
required to be excluded
fact that the Appellant is engaged in software development activity and not rendering
technical services outside India.
b) On the facts and in the circumstances ... both software development and product development
services. No information is available on the segmental bifurcation of revenue from
sale of products and software services
expenditure was attributable to the delivery of software outside
India or for providing technical services outside India. The
IT(TP)A No.675/Bang/2012 ... above
expenditure was attributable to the delivery of software outside
India or for providing technical services outside India. In the
alternative, if the same
disclosure,
the company's operations predominantly relate to providing software technical
consultancy services to its sole customer Fujitsu Services Limited. The ld AR argued ... software consultancy services which is not
similar to assessee business. The assessee is engaged providing software development
services, payroll services and corporate training services
engaged in the business of software
development and rendering technical services outside India in the field
of computer software. For the assessment year under consideration ... case, the assessee is
engaged in the business of software development and rendering of
technical services outside India in the field of computer software
Elxsi operating two segments -system communication
services and software development services. The TPO accepted the
software development services segment in his T.P. analysis ... software development services
segment itself comprises of three sub-services namely (a) product
design services (b) design engineering services and (c) visual
computing labs
