with Article 12 of
Indo-US-DTAA?
2) Whether supply of software on license is
royalty/included services within the meaning
of Section ... received by the respondent Assessee on grant
of licences for use of software is not royalty
within the meaning of Article
export-oriented undertaking from the
export of articles or things or computer software for a
period of ten consecutive assessment years beginning with
the assessment ... undertaking begins to manufacture or produce articles
or things or computer software, as the case may be, shall be
allowed from the total income
Commissioner Of Income Tax Ii vs Software Consultants on 17 January, 2012
Author: Sanjiv Khanna
Bench: Sanjiv Khanna , R.V.Easwar
$~26.
*IN THE HIGH ... INCOME TAX II..... Appellant
Through Mr. Kiran Babu, Sr. Standing
Counsel.
versus
SOFTWARE CONSULTANTS ..... Respondent
Through Mr. Salil Aggarwal, Advocate.
CORAM
Director Of Income Tax (Exemption) vs National Association Of Software And ... on 10 May, 2012
Author: R.V. Easwar
Bench: Sanjiv Khanna , R.V. Easwar ... Standing Counsel with Ms.Anshul
Sharma, Adv.
Versus
NATIONAL ASSOCIATION OF SOFTWARE AND
SERVICES COMPANIES ....Respondents
Through: Mr. Ajay Vohra, Ms. Kavita
customer. For
example, special skill or knowledge will be required to
develop software and data used in a computer game that would
subsequently be used ... involve the provision of the use of, or access to, data and
software (see, for example, categories
deduction under Section 10B was setup by HICS after approval of
Software Technology Park India (STPI) dated 8th July, 1999.
Subsequently, this undertaking owned ... export-oriented undertaking
from the export of articles or things or computer
software for a period of ten consecutive assessment
years beginning with the assessment
respondent-assessee was, therefore, not involved in the
development of computer software or information technology enabled
services as the use of technology was not quintessential ... were raised on 31st March, 2007 after obtaining Software
Technology Parks of India (STPI) approval for the said unit at Bangalore.
5. Commissioner of Income
Assessee is a company which is involved in the
business of software development. The commercial
operations started in the Financial Year 2002-03. The
Assessee ... provides wireless solutions for mobile
consumers and enterprises. The software
development relates to the field of instant messaging
(IM). It employed and functioned with
APPEAL NOS. 797/2006, 951/2006,
961/2006, 390/2007
ORACLE SOFTWARE INDIA LIMITED
..... Appellant
Through Mr. M.S. Syali, Sr. Advocate with
Ms. Husnal ... These 10 appeals by the assessees-Oracle India Private Limited
and Oracle Software India Limited relating to Assessment Years 1994-
95 to 2004-2005 raise
holding that income earned by the
appellant from development of software
upgrades for Network Management Systems
for smooth and trouble free working of VSAT
service ... confusion as the
Assessing Officer has made several additions including addition
for software sales, domestic satellite services etc. There is no
clear and direct finding
