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with any person in India including provision of download of data or software in India, if the aggregate of payments arising from such transaction

assessee is engaged in different types of business activities, viz., software development services and IT services; manufacture of Vanaspati/Hydro generated oils; toilet soaps; lighting ... generated from non-STPI/non-SEZ undertakings. STPI refers to "Software Technology Park" and SEZ refers to "Special Economic Zone". This

which was passed by the Hon'ble DRP accepting software distributors as appropriate comparable to benchmark the Appellant's international transactions; 7. erred ... Appellant under section 92C of the Act and disregarding the fact that software distributors are appropriate comparables to benchmark MSMD's international transaction

justified in treating the software expenses of Rs. 39,58,659/- [55,16,940 - 15,58,281] as revenue expenditure ignoring that the said expenses ... assessee and also without ascertaining the nature / utility of the software, it is simply not possible for the Assessing Officer to ascertain whether software were

Qatalys Software Technologies Private ... vs Union Of India on 11 March, 2020 Equivalent citations: AIRONLINE 2020 MAD 303 Author: Subramonium Prasad Bench: A.P.Sahi ... Qatalys Software Technologies Private Limited rep. By its Director Kharedehal Venkata Abhiram Krishna S-16 Siddarth Thiru.Vi.Ka.Industrial Estate Guindy Chennai

Director Of Income Tax (Exemption) vs National Association Of Software And ... on 16 January, 2020 Bench: A.M. Khanwilkar , Dinesh Maheshwari 1 IN THE SUPREME ... DIRECTOR OF INCOME TAX (EXEMPTION) APPELLANT(S) VERSUS NATIONAL ASSOCIATION OF SOFTWARE AND SERVICES COMPANIES (NASSCOM) RESPONDENT(S) O R D E R 1. Learned

captive service provider as opposed to the comparable companies who were independent software service provider. 2.8 That on the facts and in the circumstances ... assessee is engaged in the business of software development, maintenance and IT enabled services. It filed its return of income on 29/11/2012 declaring

length price of the 'international transactions' of provision of software development services undertaken with the associated enterprise on the basis of order passed ... retain the company only if segmental profitability of company with respect to software development services (IT segment ) is available. 2.6 Without prejudice, that

subsidiary of Exeter Educational Management Systems Inc. USA and provides software development services for the administration of higher education institutions worldwide. The Assessee is engaged ... business of providing software development (technical support) services to its overseas Associated Enterprises ('AE' for short). It is not in dispute that

deleting the addition of Rs. 24,25,168/- being transaction with EDP Software Ltd. ignoring the fact that the assessee is holding all the shares ... with respect to advance received from EDP Software Ltd. The basic grounds of additions by the Assessing Officer were that fresh advances have been given