engaged in the activity of trading of generic software and
providing customized software development services for
domestic as well as for foreign clients through ... centres of the
14
Respondent. However, in the process of such customized
software development, certain activities were required to be
carried out at the sight
trading
ITA.No.496/2017
-7-
of generic software and providing customized
software development services for domestic as well
as for foreign clients through ... development centres of the Respondent.
However, in the process of such customized
software development, certain activities were
required to be carried out at the sight
engaged in the activity of
trading of generic software and providing
customized software development services for
domestic as well as for foreign clients through ... software technology parks;
commencing on or after the 1st day of April,
2001, in any special economic zone.
16. The 'software technology park
include development of software, testing of
software, domestication of software and since the assessee is engaged
in developing and providing software to meet the need ... software development is possible without technical
services; software development and technical services are two faces of
one coin and there cannot be software without rendering
year 2017 and the loan was
3
sanctioned to the customer in the year 2015 and the trial Court
erroneously concluded that accused therein executed ... remitted
out of India to mainly five concerns towards purchase of customized
software. Rs.111.60 crores were transferred to other entities in India
primarily
engaged in the development of software products
and particularly in customized software solution
like DXchange, Carma etc. products. The Tribunal
after considering the functions
connected appeals Page 5 of 6
services. Rather it uses specific customized software, which is
specific to its banking activities
crores remitted outside India to 5
concerns towards purchase of customized software and
Rs.111.60 crores were transferred to other entities of India.
Most
engaged in the activity of trading of
generic software and providing customized
software development services for domestic as
well as for foreign clients through
crores remitted
outside India to 5 concerns towards purchase of customized
software and Rs.111.60 crores were transferred to other entities
of India. Most
