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
four categories:
i) The first category deals with cases in which computer software is
purchased directly by an end-user, resident in India, from ... resident Indian companies
that act as distributors or resellers, by purchasing computer software
from foreign, non-resident suppliers or manufacturers and then
reselling the same
since they contained and
formed part of the technical know-how which was part of a
technical collaboration between the importer of the
drawings ... Tata Consultancy Services
Vs. State of Andhra Pradesh (supra) for the purposes of
levy of sales tax on computer software. It was held
technical assistance in any manner in one
or more disciplines of engineering [but not in the discipline of
computer hardware engineering or computer software engineering ... installation;
(zzh) to any person, by a technical testing and analysis agency,
in relation to technical testing and analysis;
(zzq) to any person
itself
to prevent virus in the computer system. Once the
computer system is booted, the Antivirus Software
begins the function of detecting the virus, which ... software.
G. reduce any part of the software to human readable
form. H. use the software in the creation of data or
software used
limited company carrying on the business of software
development, hardware sales, technical training and engineering
9
services. Assessee exports software from its industrial units ... limited
company carrying on the business in software development,
hardware sales and technical training and engineering services.
It has software export unit situated
short,
“BALCO”) for providing “Design Engineering Services” and “Project
Management & Technical Services”. In terms of the said agreement, it
rendered “Consulting Engineer Services ... disciplines of engineering including the discipline of computer
15
hardware engineering but excluding the discipline of computer
software engineering;
xxx xxx xxx xxx xxx
Explanation
export
of India [‘STP’], since the
pg. 15-16 of of computer software.
year 1995. As per the
Paperbook Vol I)
agreement between [Impugned Order ... exemption u/s 80HHE
[Deduction of profits from
export of computer
software] and later u/s
10A/10B [deduction of
profits and gains
State (N.C.T. Of Delhi) vs Navjot Sandhu@ Afsan Guru on 4 August, 2005
There is neither any
23
BALCO v. Kaiser Aluminium Technical Services Inc., (2012) 9 SCC 552; Howard de Walden
(Lord ... intended to attract
the rigours and technicalities of Section 31 of the LA Act, it would have
used the requisite phrase. It is submitted that
