pricing study:
•Ask Me Info Ltd.
•MCS Ltd.
•CMC Ltd.
•C.S. Software Enterprise Ltd
•Mphasis BFL, Ltd.
•Tata Share Registry Ltd.
•HCL Technologies ... Capital Markets (India) Pvt. Ltd.
•R Systems International Ltd. (Seg.)
•Flextronics Software System Ltd. (Seg.)
•Asit C Mehta Financial Services Ltd (Erstwhile Nuclear Netsoft
convenience.
2. The assessee is engaged in the business of providing software
development services and marketing support services to its Associated
Enterprises (AE). The services ... Appellant had any motive of tax
evasion.
GROUNDS RELATING TO TP (SOFTWARE
DEVELOPMENT SEGMENT)
5. The lower authorities have erred in making transfer pricing
adjustment
Circle- 7, Pune. Vs Intelligence India Private Limited,
(Formerly known as MSC Software
Corporation India Private Limited),
Unit Number: 101-105, 1st Floor,
Sai Radhe ... Intelligence India Private Limited, Vs Circle- 7, Pune.
(Formerly known as MSC Software
Corporation India Private Limited),
Unit Number: 101-105, 1st Floor, Sai
Radhe
subscription charges paid to 3 3
Forester Research and Gartner
Disallowance of software expenses for not - 4
deducting TDS
Disallowance of software expenses as capital ... Assessee is an Indian Company engaged in development
and export of computer software. For the year under consideration,
original return of income was filed
appellant in respect of the international
transactions in connection with provision of software development
services undertaken by the appellant with its Associated Enterprises ... Year 2011-12. The
assessee company is engaged in the business of software development and exports.
The assessee is an Indian entity of Computer Science
made by the TPO in respect of the software development
services ('SWD services' for short) rendered by the
Assessee
5. Ground
executed
by the Appellant in favour of M/s Nishtha Software Pvt. Ltd. A
Memorandum of Understanding ("MoU") dated 20.02.2010 was
entered between ... Corporate Debtor. A Development Agreement was entered
between M/s Nishtha Software Pvt. Ltd. and M/s Earth
Infrastructures Pvt. Ltd. for land area
receipts are
towards use of hardware/ infrastructure comprising of server, software,
data storage space, networking equipment, databases, etc., and hence
constitutes 'royalty', being ... have
control or possession on any hardware/ infrastructure comprising of
server, software, data storage space, networking equipment, databases
used by the appellant to provide
Worldwide Limited 0.52
2. Caliber Point Business Solutions Ltd. 18.09
3. CGVAk Software Limited 2.39
4. Cepha Imaging Private Ltd. 2.06
5. Informed Technologies India ... comparables from the final set of comparables.
(A) For inclusion :
(i) CGVAk Software Limited
(ii) Informed Technologies India Ltd.
(iii) R. Systems International - BPO services
upholding the action of the
Assessment Unit /TPO/NaFAC in including Fuzen
Software Private Limited in the final list of comparables,
which ought ... companies:
Jindal Intellicom Ltd.
I S N Global Solutions Pvt. Ltd.
Fuzen Software Pvt. Ltd.
Motif India Infotech Pvt. Ltd.
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