engaged in the
business of development and export of computer softwares and
rendering technical services.
(b) The Respondent has shown gross income from business ... 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
resident manufacturer along with
a computer or computer-based equipment under any scheme approved under the Policy on
Computer Software Export, Software Export, Software Development ... works such as dramatic or musical work,
computer programme,
The question of royalty in respect of computer software has to he decided on the basis
case were that the assessee was a software company engaged in
software development, software export and allied activities, that a TDS
Survey ... render any technical services either
to the Interconnection Seeker or to the Subscriber of the services, that
just because technical equipment/gadgets were used
treasury services and risk
management services
7.3 The DCIT and DRP have failed to consider that
the management services rendered are neither
technical services ... that STIPL is
rendering managerial, technical and consultancy services to
the assessee by providing services of technical or other
personnel. Thus the services come within
rendering of any
managerial, technical or consultancy services (including the provision of services of
technical or other personnel) but does not include consideration ... because the expression 'technical services'
takes colour from the expressions 'managerial services' and 'consultancy services'
which necessarily involve
into data
analytical services; operation management services;
accounts reconciliation services which are aimed at
reducing process errors and operational risks and that ... Citigroup to its corporate and retail
clients. Technical services involve software testing,
verification and validation of software at the time of
implementation and data centre
reverse engineering, selling or licensing the
software product or the copyright in the software product or
using the software product for any purpose other than ... programs, containing instructions for a computer required
either for the operational processes of the computer itself
(operational software) or for the accomplishment of other tasks
consist of development and transfer of
technical plan or technical design shall be
treated as fee for technical services. An
identical issue has been considered ... consist of development and transfer of
technical plan or technical design shall be
treated as fee for technical services. An
identical issue has been considered
facts, even the payments for the warranty services and
support services, can be treated as fees for technical services in
view of provisions of paragraph ... rendering of
any technical or consultancy services (including through he provision of services
of technical or other personnel) if such services:
(a).....................
(b) make available
things or computer
software outside India or the expenses, if any, incurred in foreign
exchange in providing the technical services outside India ... things or computer software outside India, or expenses if
any incurred in foreign exchange, in providing the technical services
outside India should not be included
