Mentor Graphics (India) Pvt. Ltd. engaged in the
business of software development. The assessee company filed its e-return of
income ... functionally similar to the assessee company.
However, Infosys is engaged in providing software consulting and products,
application design, development, re-engineering and maintenance, system
integration
accounts receivable etc.
2.1 During the year under consideration, the assessee provided
software development services (CSD) , information technology
enabled services (ITES), marketing support services ... Transactions INR final AO order
(in INR)
1. Provision of software 2,822,539,489 Transactional Nil
development services Net Margin
Method
("TNMM
operation in the
year 2002. It is mainly engaged in the providing software
development services (IT) and information technology enabled
services (ITeS) to its associated ... enabled services team of ATI comprises of 1,075
people.
Software development division:- The nature of services
rendered by the software development division
Design Systems Inc. and was
established in India in order to undertake software development and research
services, related information technology, back office support service ... unit located in the Noida Special
Economic Zone (SEZ) and the Software Technology Parks (STP) unit located in
Bangalore. Further the IT group in India
negotiations, presentation and clarifications, signing the contract, manufacture of
hardware and software, actual supply, commissioning and testing, training of
engineers of Indian customers in network ... repair service, supply of spares without extra charges till warranty
period, removing software bugs and supply of software updates without extra
charges till warranty period
Acropetal Technologies Ltd. (Information Technology 22.06%
No.
2 Akshay Software Technologies Ltd. (%)*
0.86%
3 services segment)
Celstream Technologies Private Ltd. 13.20%
4 e-Infochips India ... Solutions Ltd. 21.51%
13 Persistent Systems Ltd. 23.08%
14 R S Software (India) Ltd. 16.20%
15 Sankhya Infotech Ltd. (software development 26.20%
16 Sasken Communications
significant
intangibles but uses the trademark process, knowhow, technical data
software, operating/ quality standards etc. developed and owned by
the group companies. Thus, assessee ... total turnover, hence
not a suitable comparable
3. C G-VAK Software & Exports Significant income of the company
Ltd. is from software development
divisions namely Semi Conductor Product
Centre, International Transactions of providing Chip design / software
development services were entered into with associated enterprises
aggregating ... price of the
international transactions entered into with its AE of providing software
development services. The assessee company was taken as tested party and
operating
being taken up for final
disposal on all other grounds.
PROVISION OF SOFTWARE DEVELOPMENT SERVICES (Hyderabad Unit)
3. The first issue raised by the assessee ... Assessing Officer (AO) in the international
transaction of ` Provision of Software Development services'.
4. Briefly stated, the facts of the case are that
Gurgaon) Pvt. Ltd. vs. ACIT, New Delhi
(banking and insurance), high-tech, software, electronics,
engineering, nanotechnology, networking, biomedical engineering),
telecom equipment and operators, pharmaceutical ... basis that it had engaged itself in processing and
providing software development and consultancy and engineering
services/web development services. The reasons for execution were
