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 ... software including services for the development of such software outside India is
deemed to be the profits and gains derived from the export of computer
derived income from sale of software
services and products. There is no segmental information in respect of
software services and products therefore this company cannot ... earned revenue from three segments
i.e. software services and software products and other services. He has
contended that there is no segmental information available
engaged in the business of development
and export of computer software and technical services, filed its return
of income for Assessment Year ... business
acquired certain application software. The amount is paid for application of software and not
system software. The application software enables the assessee to carry
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
engaged in the business
of rendering software development services. The Assessee renders services to Anshin
Software Corporation, USA incorporated as a company under the laws ... software service provider as this company
was into both the business of Software Development Services (IT) as well as providing
Information Technology Enabled Services (ITES
rendering of any managerial technical or
consultancy services (including the provision of services of technical or
personnel) but does not include consideration for any construction ... technical services in
nature or character. The services rendered in the course of rendering agency
services are essentially business services and to obtain the business
providing services relating to computer
development and deployment falls within the meaning of technical
services. Accordingly, he reduced the amount ... things or computer software outside India or the
expenses, if any, incurred in foreign exchange in
providing (lie technical services outside India
design of special software and system and application of software. It is also
engaged in the business of rendering technical services related to tabulation,
coding ... design of special software and system and application of
software. The assessee is also engaged in rendering technical services related to
tabulation, coding and software
rendering of any managerial, technical or
consultancy services (including the provision of services of technical
or other personnel) but does not include consideration ... rendering of any managerial, technical or
consultancy services (including the provisions of services of technical or
other personnel) but does not include consideration
maintenance of laptop, computer, servers
and specialized software require the services of highly
professional and technical persons and cannot be done
by non-qualified persons ... utilized the services of
production houses. The AO was of the opinion that these
services rendered by these production houses were highly
technical in nature
