Commissioner of Income tax of Appeal, Trichy failed to see that
Software expenses are of revenue expenditure as per Income tax appellate Tribunal
order dated ... 2003 for A Y 94-95).
(ii) The life of the software cannot be determined. The software can become also
Obsolete at any time
multimedia computer graphics and animation. The assessee
also had been running a software and training division. This
software and training division was hived ... crores also related to
transferring of intellectual property rights in the software
developed by the assessee and also towards non compete
that assessee, engaged in the
business of developing and selling automotive embedded software to
group companies and also providing business outsourcing support, was
functioning ... comparable 10.06%
OP/Cost of the Assessee Company 24.09%
Income earned from software and ITES
94,72,56,794
Total expenditure incurred
claim of ` 2,13,72,000/- made by the assessee
towards software expenses, which was allowed by the Assessing
Officer ... which specified a depreciation rate of 60% for computer software.
CIT also noted that a co-ordinate Bench of this Tribunal in the case
grievance is that A.O.
treated lumpsum payment received on sale of software as royalty
under Article 12 of Double Taxation Agreement (DTA) between India ... assessee and second being lumpsum amount
received for sale of relevant software. According to A.O., receipts
3 I.T.A. No. 2137/Mds/2010
California Software Company Limited, ... vs Assessee on 27 August, 2012
IN THE INCOME TAX APPELLATE TRIBUNAL
'A' BENCH, CHENNAI
BEFORE ... 1842(Mds)/2011
Assessment Year : 2007-08
M/s. California Software Co. The Assistant Commissioner
Ltd., Robert V Chandra of Income-tax,
Tower, 7th Floor
wherein the assessee has claimed ERP solution software
expenditure of ` 50,50,000/- as revenue expenditure. The
Assessing Officer called for the explanation ... Balance Sheet. It was submitted
before the Assessing Officer that "the software provides for an
enterprise wide solution for the accounting, inventory,
production, quality
appreciate that the
observation that sale of shares in M/s Ibhar Software P Ltd
was pursuant to the pressure to sell the shares ... questions with regard to the pattern of
holding of M/s Ibhar Software P Ltd as seen from its reply to
the Assessing Officer
Object Frontier Software P. Ltd., ... vs Department Of Income Tax on 19 March, 2012
IN THE INCOME-TAX APPELLATE TRIBUNAL
CHENNAI 'B' BENCH ... Assessment Year: 2004-05
The Deputy Commissioner of M/s. Object Frontier Software P. Ltd.,
Income Tax, Vs. 7, 1st Floor, Wellington Estate,
Company Circle
Companies Act, 1956 and is carrying on the
business of software development. The assessee filed its
return of income for the assessment year ... assessee had debited a sum of `1,29,06,390/- towards
software development expenditure. The said expenditure
primarily constituted payment towards salaries for the
immediately
