Symantec Software And Services India ... vs Dcit, Corporate Circle 6(2),, Chennai on 5 October, 2018
आयकर अपील
य अ धकरण, 'डी' यायपीठ ... Chny/2018
नधा(रण वष( / Assessment Year : 2013-14
M/s Symantec Software and Services
India Pvt. Ltd., The Deputy Commissioner of
1/124, Shivaji
product idea obtained from affiliates. During the
year, it has undertaken software development services. The assessee
adopted TNMM as the most appropriate method to arrive ... ITAT
Bangalore in the case of Hewlett Pack and (India) Software Operation P. Ltd.,
[2016] 67 Taxmann.com 309 (Bangalore- Trib) in IT(TP) Appeal
under the Act as against 10%.
Ground 4 - Depreciation at 25% on software license as
against 60% claim of depreciation is unwarranted ... facts and circumstances of the case, the CIT(A)
erred in reclassifying software license under the block of
Intangibles assets, thereby resulting in restriction
disallowed the expenditure incurred towards purchase of
software from tax resident of Japan and United Kingdom by
treating it as taxable income in India ... assessee's associated companies and payment made towards
purchase of software from tax residents of Japan and United
Kingdom, abroad.
4. Ground
towards payment made for software licenses without
deducting tax at source
(iii) The Ld.CIT(A) has erred in deleting the disallowance
made ... Ground No.3(ii) : Disallowance of expenditure towards
software license for the assessment years 2008-09 & 2009-
10:-
During the course of scrutiny assessment
Harland Clarke Holding Software India ... vs Dcit Company Circle 2(2), Chenn on 30 October, 2018
आयकर अपील य अ धकरण, 'डी' यायपीठ ... Harland Clarke Holding Vs. The Deputy Commissioner of
Software India Pvt Ltd., Income Tax,
Suite 305,Delta Wing, Corporate Circle-2(2),
3rd Floor, Raheja
short] on the payment made towards acquisition of
software license from non-residents.
2. It was the submission of the ld. DR that the assessee ... that TDS was not made
on the remittances made towards exam fees, software license to non-
residents, etc., an order under section
Amtex Software Solutions Pvt Ltd., ... vs Acit (Osd) Corporate Range 1, Chennai on 9 February, 2018
आयकर अपील य अ
धकरण, 'सी' यायपीठ ... CHNY/2018
Assessment year : 2013-14
M/s.Amtex Software Solutions Vs. The Assistant Commissioner of
Pvt Ltd., Income Tax,(OSD),
No.75,Century Centre
Amtex Software Solutions Pvt. Ltd.,, ... vs Dcit, Chennai on 23 January, 2018
आयकर अपील य अ धकरण, ''डी'' यायपीठ, चे नई ... 2015]
नधारण वष/Assessment Year :2010-11
M/s. Amtex Software Solutions The Deputy Commissioner of
Pvt. Ltd., No. 1, Commander-in-Chief Vs. Income
payments made
for software annual maintenance charges and payments made for
what is claimed as software license fees.
2. Arguing on the grounds relating ... assessee submitted that assessee
was primarily engaged in the business of software development.
According to him, during the relevant previous year, assessee had
paid annual
