engaged in the activity of trading 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
software
development and related services/solutions; and it provides / exports
customized software services and related solutions mainly to its associated
enterprises situated outside India. During
engaged in the activity of trading 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
holding that
expenses claimed towards acquisition of License to use MATFLOW
software through a service arrangement with Danfoss IT Denmark
Company is acquisition ... systems which is uniform/customs made for usage among the
group companies and for support software to supplement routine
operations and therefore
identifying the candidates for its foreign customer, amount to
export of articles or things or computer software for being eligible
for deduction under section
software development
and they render services to its wholly owned subsidiaries outside India, City
Group entities and also unrelated third party customers. For the assessment
thus:
2.1. The appellant company is engaged in the business of providing
software solutions to banking, financial and insurance industry, besides they ... been creating larger amount of software using the capital equipment viz.,
computers. It is further contended that creation of software is eligible for relief
M/S.Mobis India Limited vs Deputy Commissioner Of Income Tax on 1 September, 2022
Pentamedia Graphics Limited vs The Assistant Commissioner Of Income ... on 3 March, 2022
Bench: R
