India have to be computed separately in respect of hardware and software
components of the telecom equipment and the mobile handsets.
5. The assessee ... contended before the AO that the software
embedded in the telecom equipment or provided to the customers separately,
or software supplied to the various customers
Infonox Software Pvt. Ltd. And Ors. vs Raj Kumar Dubey And Anr. on 11 January, 2017
Equivalent citations: 2017 (6) ADR 310, (2017) 177 ALLINDCAS ... 2017 and CM Nos. 1087-89/2017
INFONOX SOFTWARE PVT. LTD. AND ORS. ..... Petitioners
Through Mr.Akhil Sibhal, Mr.Ajoy Roy,
Mr.Aman Avinav
Commissioner Of Income Tax Vadodara ... vs Nexus Software Ltd on 8 December, 2017
Bench: R.K. Agrawal , Abhay Manohar Sapre
ITEM NO.10 COURT ... Ahmedabad)
PR. COMMISSIONER OF INCOME TAX VADODARA 2 Petitioner(s)
VERSUS
NEXUS SOFTWARE LTD Respondent(s)
( IA No.128170/2017-CONDONATION OF DELAY IN FILING
have not altered.
5. Determination of arm's length price for Software Segment
5.1. The Learned AO, TPO and DRP erred in making ... adjustment to the
ALP of international transactions relating to software development services
rendered by the Appellant and in not accepting the ALP of the international
grossly erred on facts in benchmarking the transactions of the
captive software services of the Appellant with companies operating as full
fledged entrepreneurs without considering ... grossly erred on facts in arbitrarily rejecting companies having
software development revenue less than 75% of total operating revenue.
g) The AO/TPO erred
Astral Pharmaceuticals Industries ,, ... vs The Dy.Cit, Circle-1(2),, Baroda on 21 September, 2017
Provident Inv. & Industries (P) Ltd., ... vs Ito, New Delhi on 17 May, 2017
Provident
2004. Under this agreement, the assessee was obliged to
provide software connectivity to subscribers in the territory of India,
Bangladesh & Nepal to access ... system and other software
products developed by 'Amadeus Spain' available on the host. For
providing this access, the assessee performs various data processing
Dcit 7(2), Mumbai vs Albright & Wilson Chemicals India Ltd, ... on 24 April, 2017
payment made to M/s. Minitab Inc., USA for
acquisition of software by treating the same as 'royalty'
chargeable to tax in terms ... made to
M/s. Minitab Inc. (USA) for the purchase of computer software
does not amount to business receipts in terms of Article
