rendering of any managerial,
technical or consultancy services (including the provision of
services of technical or other personnel) but does not include
consideration ... computing income by way of royalties, etc.,
in case of non-residents.
44DA. (1) The income by way of royalty or fees for technical
services
undertaking from the export of articles or things or
computer software for a period of ten consecutive
assessment years beginning with the assessment year
relevant ... deduction, in computing the total
income of an undertaking, which begins to
manufacture or produce articles or things or
computer software during the previous year
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
other categories of software,
these being network software and language software. The network software
enables groups of computers to communicate with each other, while
language ... business
acquired certain application software. The amount is paid for application
of software and not system software. The application software enables the
assessee to carry
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 ... rendering of any managerial, technical or consultancy services
(including the provision of services of technical or other personnel) but
does not include consideration
Vikas Sharma (A-10), M/s. Real
Technical Solution Ltd., (A11), M/s. Jaibharath
Technical Services Pvt. Ltd., (A-12), M/s. Industrial
Techno Manpower ... West Mining Ltd., (A7), M/s. Real Technical Solutions
Pvt. Ltd., (A11), M/s. Jaibharath Technical Services
Pvt., Ltd., (A12) and M/s. Industrial Techno
rights (including the
granting of a licence) in respect of computer software supplied ... 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
page
552 between Bharat Aluminium Company and Kaiser
Aluminium Technical Services Inc. So far as the said
contention of the learned counsel for the respondent ... standards, supplements of standards, training and
other materials furnished to him, computer
software and data based material, customer list,
admission records, other records and files
said services
are essential for export of
services.
Business Support ITSS These services are availed in
Services order to avail the services of
payroll processing ... coaching export software services.
services
Renting of ITSS These services are availed to
immovable property use the premises from where
services the services are exported
states
that it supplies telecommunication equipment (hardware) along with
software from outside India to various telecom companies in India. The case
of ALF is that ... India, it derives income in the nature of fees for technical
services (FTS), royalty and interest, which is offered to tax on gross basis
