things or computer
software outside India or expenses, if any, incurred in foreign
exchange in providing the technical services outside India."
18. While computing ... year, it was engaged in
development of computer software and not in rendering any technical
services. Communication expenses were incurred not for export of
computer
these expenditures had been incurred by the assessee in relation to
technical services rendered by it outside India and is therefore liable to be
reduced ... expenses incurred
in foreign currency attributable to delivery of computer software for providing
technical services outside India to be excluded both from export turnover
business of software
development, maintenance services and business process outsourcing services and had
three units in operation:
(a) Software development unit in respect of which ... business of software
development, maintenance services and business process outsourcing services and
had four units in operation:
(a) Software development unit ("Leela Galleria unit
things or computer
software outside India or expenses, if any, incurred in foreign
exchange in providing the technical services outside India."
4. While computing ... year, it was engaged in
development of computer software and not in rendering any technical
services. Communication expenses were incurred not for export of
computer
requiring any adjudication.
Software services segment
9. As far as software services segment is concerned, the TPO
computed the ALP of the international transaction ... year, it was
engaged in development of computer software and not in rendering any
technical services. Communication expenses were incurred not for export
of computer
Technical Support Services". Under
the Software Development service segment, the assessee provided
contract software development services to its associated
Enterprises. The functions performed were ... opinion the
software development services rendered by the assessee
cannot be compared with a whole basket of services of
consulting, technical support or management services
begun or begins to manufacture or produce
articles or things or computer software during the previous year relevant to
the assessment year commencing ... deduction, in computing the total income of an undertaking, which begins
to manufacture or produce articles or things or computer software during
the previous year
Software Technologies Limited 8.24%
Aztec Software & Technology Services
3 13.94%
Limited
4 Bangalore Softsell Limited 4.37%
5 Bristlecone India Limited -2.92%
6 Compucom Software ... Technical assistance and clarifications
We understand that APCC US provides technical assistance,
information and certain technical clarifications in the provision
of technical support services provided
rendering of any managerial, technical or consultancy services (including the
provision of services of technical or other personnel) but does not include
consideration ... 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
assessee was engaged in the
business of providing engineering, software and technical design services with
use of Computer Aided Design (CAD), Computer Aided Manufacturing ... under:-
i) Procurement of spare parts and components;
ii) Technical and field implementation services
iii) Payment of royalty fees; amortization;
iv) Availing professional consulting services
