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
technical services rendered in
connection with export of computer software and export
of technical services for the purpose of development or
production of computer software ... should consider what is "software"and
what is "technical services". Explanation (ii) to sub-
section 9A of Section 10B defines computer
technical services rendered in connection with export
of computer software and export of technical services
for the purpose of development or production of
computer software ... testing, installation and monitoring
of software supplied to the client. Though the said
services are technical in nature it does not fall within
clause
software
(including services for development of
software) outside India shall be deemed
to be the profits and gains derived from
the export of computer software ... software (including services for development
of software) outside India shall be deemed to be the
profits and gains derived from the export of computer
software
order dated 22.12.2008 inter alia held that technical
service for delivery of computer software of the nature
provided by the assessee is methodical, mechanical,
procedural ... held that onsite development of computer software
cannot be held to be rendering technical services outside
India and it cannot be reduced from export turnover
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
undertaking from
the export of article or thing or computer software?
(3) Whether on the facts and in the circumstances of
the case, the Tribunal ... postulate that the expenditure incurred in
foreign exchange in providing technical services outside India
has to be reduced from the export turnover only
agreement stipulated not only the Midrex
process licence, but also some technical services provided
by Midrex, for which respectively ... plant.
10. Tata Consultancy Services was a case in which
the specific issue of computer software packages, was
O.T.Rev.171/2015
mention. The assessee is in the business
of export of software solutions and maintenance
services. The assessee filed the return of income ... units, in respect
of cost of materials / services. However, in respect of
payments to sub contractors, royalties, technical fees,
communication expenses, the assessee estimated
2018 Page 1 of 27
Technology Solution and Services including supply of computer
hardware, software, etc. The respondent has been established by the
Ministry ... respondent
availed the services of the petitioner upto 08.07.2015. In fact, the
petitioner had provided the services of its Technical Support Staff even
OMP (COMM
