respect of the
assessees' income derived from export of computer software was
permissible."
2. The facts pertaining to the cases ... engaged in 100% export of
artware handicrafts, home furnishing and software exports. The
assessee had three divisions respectively, in connection with the said
three activities
such
outcome; the result is of no universal application; unlike software, it does
not facilitate production of goods or services ... follows:
"From the details of Oracle Applications, we find that the
software on the Master Media is application software. It is not
an operating
only activity which
qualified for the benefit was "computer software development" and that the
assessee's activity i.e. programme management services ... open a unit and was granted permission to do
so in a Software Technology Park on 27.4.2004 in Chennai; such being the case,
the Assessing
proceedings?
(ii) Whether the Tribunal fell into error in holding that the software
expenses to the extent of `2,69,35,669/- incurred ... incurred a sum
of `2,69,35,669/- towards software expenses. The assessee claimed the installation
expenses as a deduction, debiting it to the profit
Adobe Systems Software Ireland Ltd. vs Assistant Director Of Income Tax on 28 March, 2014
Author: R.V. Easwar
Bench: S. Ravindra Bhat ... 2328/2013
+ W.P.(C) 2330/2013
ADOBE SYSTEMS SOFTWARE IRELAND LTD. ..... Petitioner
Through: Mr. M.S. Syali, Sr. Advocate with
Mr. Vishal Kalra
relying upon the approval for setting up Software Technology
Parks in India by virtue of a certificate dated 8.12.2006 issued to it.
3. It claimed ... deduction of `38,98,220/- in respect of the income
from software exports for the entire previous year
account the Assesse has claimed
W.P.(C) 759/2013 Page 1
software expenditure of Rs. 129.70 lakhs as revenue
expenses. By treating the software ... case for the Assessment Year 1999-
2000 has treated the software expenses as capital
expenses.
In this case 4 years have elapsed from
company
engaged in the business of information technology education and export of software
services. We are concerned with the assessment year 1999-2000, the relevant ... world-wide income and
allocation of expenses towards learning business and software business. While so, on
01.04.2010 the CIT passed orders under Section
Bench's decision of the ITAT in the case of Aztectech Software
& Technology is against the assessee. This is against the
assessee. This
adjustment of Rs.5.98 crores on account of
additional compensation for software services transactions. The AO
prepared a draft assessment order
