Software Corporation India Pvt. ... vs Acit, Circle 11(2), Pune on 22 March, 2017
आयकर अपील य अ धकरण पण
ु े यायपीठ ... 2013
नधा'रण वष' / Assessment Year : 2008-09
MSC Software Corporation India Pvt. Ltd.,
6th Floor, Amar Apex Building,
Near Baner Telephone Exchange
assessee company is engaged in the business of software product development and is 100% E.O.U. unit approved by Software Technology Park of India ... also taken as leading provider of customer service and contact center software based on integrated communication platform. The taxpayer has further claimed exemption Under Section
accepting the international transaction with respect to the
software engineering services segment to be at arm's length. However, the
Assessing Officer ... undertaking from the export of articles or
things or computer software for a period of ten assessment years beginning with
the assessment year relevant
Income-Tax Officer,, vs Magic Software Enterprises India Pvt. ... on 31 January, 2017
आयकर अपील�य अ�धकरण पुणे �यायपीठ "ए" पुणे ... Income Tax Officer,
Ward 11(1), Pune .... अपीलाथ�/Appellant
Vs.
Magic Software Enterprises India Pvt. Ltd.,
9/12, Tara Icon, Mumbai Pune Road,
Wakadewadi,
Pune
DCIT -
ITA No.1350/PN/2010
2. ACIT Vs. Symantec Software Solutions Pvt. Ltd. -
ITA No.8673/Mum/2011
3. Global Logic India ... also. One of the issue raised is regarding the inclusion
of Compucom Software Ltd. as a comparable by the TPO. Such inclusion
is assailed
assessee in all the units
were engaged in the business of software development and its exports and
was admittedly, entitled to claim the deduction under ... claim of assessee that the net margins of 26.99%
earned from the software development services was not more than ordinary
profits, was accepted
case.
5. It is to be noted that in the case of software industry, the number of
players involved are many and for each range ... report of Dun and Bradstreet, it had classified the
software companies into the following categories;
a. Large size firms (Rs.20,000 Mn)
b. Medium
arriving at adjustment in computation of arms length price in
respect of software development services of the Appellant.
3. That on the facts ... Order.
(b) Arriving at a set of companies as comparable to the software
development services of the Appellant, by rejecting companies that are
otherwise functionally
treating the license fees paid on account of user of computer software programme as capital expenditure as laid down in Section ... shows that such license fees were paid for use of the 'Software System' sans ownership, control and are different and distinguishable from
that the assessee is a company
engaged in the business of embroidery software designing and
document creation. It filed its return of income ... which are as under :
Sr.No. Company Operating
Margin Ratio
1 Ace Software Exports Ltd., 0.63%
2 C.S. Software Enterprise Limited 17.37%
3 Genesys
