deleting the disallowance made on account
of expenditure on imported software u/s.40(a)(i) of the Act on account of
non-deduction ... that the assessee has claimed expenditure incurred in respect of
purchase of software called upon the assessee to furnish the necessary details.
On verifying
Limited Company and is engaged in the
business of export of computer software providing e-solutions, BPO
activities and other management consultancy activities. During ... raised in assessee‟s appeal pertains
to expenditure incurred on import of software.
13. The brief facts of the case pertaining to this issue
Agilent
Technologies, Inc. The assessee is engaged in the provision of Software
Development (IT) services and Information Technologies Enabled Services
(ITES). It filed its return ... under:-
2
ITA No.6047/Del/2012
2.2 So far as the Software Development Segment is concerned, the TPO noted
that the tax payer
your good self may appreciate, the EEC /
software segment ls an entirely captive service
segment and hence, the provision for doubtful
debts and warranty have ... segment as
there are no cost base transactions in the EEC/
software segment while the J3 segment was
started only in AY 2014-15. Hence
relief
granted in respect of addition relating to transfer pricing
adjustment in Software development services. Besides the same,
the revenue has also raised a ground ... challenging the direction given
by Ld CIT(A) to grant depreciation on software purchases.
4. In the cross objection and additional Cross objection, the
assessee
Software Communications Pvt. Ltd, ... vs Acit Cir 16(1) , Mumbai on 22 April, 2022
ITA No.2024/Mum/2021 A.Y.2013 ... Software Communications Pvt. Ltd. Vs. ACIT, Circle 16(1)
THE INCOME TAX APPELLATE TRIBUNAL
"F" BENCH, MUMBAI
BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER
Length Price ("ALP") of the
international transaction pertaining to software
development services.
4. The learned AO/learned TPO/Hon'ble DRP erred ... have been included'as comparables:
a) Acropetal Technologies Ltd.
b) Akshay Software Technologies Pvt. Ltd.
c) Cigniti Technologies
d) Helios & Matheson Information Technology
whichever is more beneficial.
4. Non-deduction of withholding taxes on outsourced
software services - INR 76,873
a) Online Purchase of Software ... disallowing the payment made towards online purchase of
standard shrink wrapped software which is available 'off the
shelf on the ground of failure
Software India Private Limited, ... vs Deputy Commissioner Of Income-Tax ... on 9 September, 2022
IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH, PUNE ... JUDICIAL MEMBER
ITA No. 270/PUN/2021 : A.Y. 2016-17
BMC Software India P. Ltd.,
Business Bay, Wing I, Tower B,
9th floor, Survey
making disallowance
of cost incurred in connection with off the shelf software products
treating the same as royalty under the provisions of the Act read ... account of costs in
connection with the shelf software products utilized for its day to day
business. According to assessee, such costs are paid
