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
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
Assessee even though is in the business of software
services, has not undertaken any software services from them
10
ITA.No.1038 to 1040 ... Hyderabad
software business and services rendered/work undertaken are
also on the field of software services, these cannot be
considered as per professional services
Beacon Global
Services Ltd was engaged in the business of export of call centre
services and not in manufacture of computer software. He
therefore, held ... business
of manufacture of computer services and it is not required that it
has also to be manufacturing computer software. For this
purpose, he placed
transaction is actually in the
nature of royalties and fees for technical services.
2 I.T.A. No.918/Hyd/2010
M/s Bartronics India ... technical services" as used in this Article means
payments of any kind to any person in consideration for services of a
managerial, technical
assessee to its subsidiaries are
to be considered as technical services coning
u/s 9(i)(vii) of the IT Act read with explanation
there ... computer software.
It had habitually engaged its subsidiaries, the four
companies mentioned in the above table, to render
software services and consultancy services
assessee Company did not export software but on
other technical grounds. So, the finding that the ISSI
provided technical services in contra distinction to
software ... technical services. The assessee has only rendered
software development services or exported software to its
customers outside India and has not rendered any technical
services
available technical knowledge, experience, skill, know
how or processes or consist of development and transfer of
technical plan or technical design. The services rendered ... technical knowledge and
application of technical knowledge, experience and skill and
as such , it will fall within the definition of fees for technical
services
towards communication expenses, which was
attributable to the delivery of computer software abroad, shown
under BPO services. Referring to the definition of 'export
turnover ... assessee for delivery of the software under BPO services
abroad, has to be excluded for computing the 'export turnover'
for the purpose
only a software product, which
would not be in technical terms much different from the
consultancy service on software project because both the
developments ... submitted that key
P&M like computers, computer software which are essential
16
ITA Nos. 710 to 714/Hyd/2014
Conexant Systems
