issue involved in this case, but was qua copyright of
computer software and payments made for use of a copyright
cannot be compared with ... 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
issue involved in this case, but was qua copyright of
computer software and payments made for use of a copyright
cannot be compared with ... 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
includes
expenses for software
development, business
development, for
ascertaining customer
requirements, etc. and that
“software development”
will not amount to
“technical services” within
the meaning ... were examined or not, but
made a standalone statement that software development and
technical services are two faces of one coin. We fail to
understand
rendering of any managerial, technical or consultancy
services (including the provision of services of technical or other
personnel) but does not include consideration ... have been defined as managerial, technical or consultancy services
including the provision of services of technical or other personnel. But the
agreement in question does
rendering of any managerial, technical or consultancy
services (including the provision of services of technical or other
personnel) but does not include consideration ... have been defined as managerial, technical or consultancy services
including the provision of services of technical or other personnel. But the
agreement in question does
includes
expenses for software
development, business
development, for
ascertaining customer
requirements, etc. and that
“software development”
will not amount to
“technical services” within ... were examined or not, but
made a standalone statement that software development and
technical services are two faces of one coin. We fail to
understand
technical
services' include development of software, testing of software,
domestication of software and since the assessee is engaged
in developing and providing software ... involve technical services
and is part and parcel of rendering services; no software
development is possible without technical services; software
development and technical services
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 ... Inspite that, learned CIT (Appeals), estimated 10% of
software development charge as charges incurred for
technical services provided outside India.
12) It is undisputed fact
deputation to foreign customers. The manpower is utilised for rendering services in computer software even in India. In the letter dated 02.12.1997, giving the note ... incentive for promoting export of computers. Thus, any technical service thus rendered in connection with the development of computer software also is taken within
certain expenses attributable to the delivery of software
outside India or in providing technical services from 'total
turnover' by the Respondent under Section ... 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
