royalties, no doubt in the context of technical
services, and remittances for supply of computer software,
which is then treated as business profits, taxable under ... resident
manufacturer along with a computer or computer-based equipment
under any scheme approved under the Policy on Computer
Software Export, Software Development and Training
technical plan or technical design.‖
9. The income of an assessee which may be discerned to fall
within the ambit of Fee for Technical Services ... rendering
of any managerial, technical or consultancy services
(including the provision of services of technical or other
personnel) but does not include consideration
development and transfer of a technical
plan or technical design and mere rendering of services
is not roped in unless the person utilizing the service ... rendering of any managerial, technical
or consultancy services (including the provision of services of
technical or other personnel) but does not include consideration
cinematographic films; television films; slide films;
slide film mounts; photographic films; computer software;
computer application software for mobile devices;
downloadable software via the internet ... publications; promotional
publications; booklets; booklets relating to games; pamphlets;
event programs; computer software in printed form;
instruction manuals relating to computer software; computer
game instruction
related services to the financial
payments industry. It had purportedly earned revenue from rendition
of software licenses and provision of software related services,
including implementation ... royalties, no doubt in
the context of technical services, and remittances for supply of
computer software, which is then treated as business profits,
taxable under
royalties,
no doubt in the context of technical services, and remittances
for supply of computer software, which is then treated as
business profits, taxable under ... difference between the
payment of royalty and the supply/use of computer software
in the form of goods, which is then treated as business
income
royalties, no doubt in
the context of technical services, and remittances for supply of
computer software, which is then treated as business profits,
taxable under ... difference between the payment of royalty and the supply/use of
computer software in the form of goods, which is then treated as
business income
photography and photographic services; digital imaging [editing of images];
film and video production; education services; publishing services; multimedia publishing
services; training services; arranging ... photographic library services; consultancy, information and advisory services relating to
all the aforesaid services; including such services provided on-line via a computer database
written in some human readable
computer programming language constituting several text files and is
a piece of computer software. In order to make a computer ... technical proprietary,
confidential information and intellectual property in respect of
'QuickLaunch SSO', a cloud based self-service software from
Plaintiff's computers
distributors/customers which is in the nature of fee for
technical services (FTS)/royalty."
12. Mr. Kumar's argument, that at this stage ... which had held against the assessee in respect
of supply of computer software to associated entities and thus dealing
with a situation similar to that
