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
Maersk Global Services Centre (India) P. Ltd. (133 ITD
543)(Mum.); Symantec Software Solutions (P) Ltd. v. Assistant CIT [2012]
25 Taxmann ... Maersk Global Services Centre (India) P. Ltd. (133
ITD 543)(Mum. ); Symantec Software Solutions (P) Ltd. v. Assistant CIT
[2012] 25 Taxmann
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
tune of ` 39,32,654.
She claimed to be a software exporter to Netherlands. The importer was one
Mr. Rolli Janssen B.V. The claim ... neither "manufacture" nor did it amount to creation of
software, he supported the orders of the AO and CIT(A). He urged that
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
Commissioner Of Income Tax (Ltu) vs M/S Espn Software India Ltd. on 7 November, 2017
Author: S. Ravindra Bhat
Bench: S. Ravindra Bhat , Sanjeev ... 2017
COMMISSIONER OF INCOME TAX (LTU) ..... Appellant
versus
M/S ESPN SOFTWARE INDIA LTD. ..... Respondent
+ ITA 890/2017 & CM No.37958/2017
COMMISSIONER
purpose of the joint
venture was production and development of computer software in India with
equity participation of `70 lakhs, by both companies ... money was
advanced by the Russian company for setting up of software development
facility in India. According to the terms of the agreement, the Russian
erred in law in not considering that the
income from supply of software embedded in the hardware equipment or
otherwise to customers in India amounts ... Cellular
Radio Telephones Systems. The assessee had supplied hardware and
software to various entities in India. Software licenced by the assessee
embodies the process which
1108/2007 are as
follows:
(i) Whether the transfer of computer software by the
Indian branch to the head office can be said ... benefit of
Section 10A of the Income Tax Act, 1961, as the software
is developed by the branch as per the requirement of Head
Office
