software and services for development of software with the
development of software from the eligible undertaking, the
consideration awarded for onsite development for computer
software ... onsite software development
services unrelated to STP undertakings. Such DTM and onsite
software services are part and parcel of the overall computer
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
deals with selling
of software products. The services provided by the IT services segment
are comparable to the software development services provided by BIPL.
Therefore ... Finance, Customer support, HR and legal services,
Consulting services, Managed services, Testing services can be classified
as IT services
things or computer software outside India or
the expenses, if any, incurred in foreign exchange in providing technical
25
services outside India. In terms thereof ... delivery of computer
software outside India or expenses, if any, incurred in foreign
exchange in providing the technical services outside India from
the export turnover
development
is also a technical service and hence, expenditure incurred in foreign
currency for providing technical service or computer software
development service should be reduced ... computer software and services for development of software outside India
within the meaning of `the profits and gains derived from the export of
computer software
including the computer software. Further, the claim of the
assessee was that the software was licensed software rather than owned
software and once when there ... provided that depreciation at 60% would be allowed on computers including
computer software. The said definition to include computer software was
introduced
software and services for development of software with the
development of software from the eligible undertaking, the consideration awarded
for onsite development for computer software ... onsite
software development services unrelated to STP undertakings. Such DTM and onsite
software services are part and parcel of the overall computer software development
projects
international
transactions pertaining to provision of software development services, IT
enabled services and sales support services.
5. Use of different turnover filter for identification ... international transactions pertaining to provision of
software development services, IT enabled services and sales support
services.
7. Accepting certain companies as comparable
business of Technical and Engineering services, Design and
Drawing, Project implementation, including computer aided design, computer
aided engineering, software management services and Finite Element Analysis ... development of
software and / or IT enabled engineering software development services. The
said concern was engaged in selling bought out software and hence not
functionally
rights of
softwares and availing other services such as maintenance of software,
2
ITA Nos.1172 to 1174/PN/2013
iGATE Computers Systems Ltd
training ... software
Serena Software Pte Purchase of general software 04.09.2007 66,990
Ltd
Cipher Soft Inc, USA Software License Fee-conversion 08.11.2007 47,784
of forms
