Abbey
National Plc, UK, can be categorized as 'fees
for technical services' under Section ... rendering of any
16
managerial, technical or consultancy services
(including the provision of services of technical
or other personnel) but does not include
consideration
activity contemplated by the Section
namely export of computer software and rendering of
technical services outside India. The income from services
rendered in India cannot ... engaged
in the export and domestic sale of computer software,
provision of technical services in and outside India and
manufacture and sale of fuel injection
technical services
rendered in post-sale services would stand on a
different footing when compared to pre-sale services. If
any technical service is rendered ... Assessing
Authority to decide whether the said technical services
rendered was in connection with the computer software
business, export of computer software
respect of profits from export of computer software where
the business entity provides technical services outside India in
connection with developments or production of computer ... derived from
37
export of computer software or under the head of 'rendering
technical services outside India' and having a nexus with
export
Software Software Software Software Software
undertaking Technology Park Technology Technology Technology Technology
Unit-I Park(India Park(India Park Unit-IV Park Technical
Development Engineering ... Computer software of Computer Services
the software and software and and software software and (Technical
undertaking software services software services services software Support)
services
Date
Software Software Software Software Software
undertaking Technology Park Technology Technology Technology Technology
Unit-I Park(India Park(India Park Unit-IV Park Technical
Development Engineering ... Computer software of Computer Services
the software and software and and software software and (Technical
undertaking software services software services services software Support)
services
Date
Software Software Software Software Software
undertaking Technology Park Technology Technology Technology Technology
Unit-I Park(India Park(India Park Unit-IV Park Technical
Development Engineering ... Computer software of Computer Services
the software and software and and software software and (Technical
undertaking software services software services services software Support)
services
Date
attributable to the delivery of computer
software outside India and expenses in
foreign exchange in providing technical
services outside India are to be reduced from ... common practice in the software
industry to depute Technical Manpower
abroad [at the client's place] for software
development activities [like upgradation,
testing, maintenance
referred to in the
aforesaid Section is business in computer
software or providing technical services. The
deduction is to the extent of the profits derived ... assessee from such business namely,
computer software export business or technical
services provided in connection therewith. Sub-
Section (3) of Section 80HHE provides
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 ... things or computer software
outside India or expenses, if any, incurred
in foreign exchange in providing the
technical services outside India.
15. Sub-Section
