Mobilox Innovations Private Ltd vs Kirusa Software Private Ltd on 21 September, 2017
Equivalent citations: AIR 2017 SUPREME COURT ... APPEAL NO. 9405 OF 2017
Mobilox Innovations Private Limited … Appellant
Versus
Kirusa Software Private Limited … Respondent
JUDGMENT
R.F. Nariman, J.
1. The present appeal
Imaging Inc.(EFI group), USA. It is engaged
in the business of software development and marketing support
services to Associated Enterprises (AEs).
3. Return ... following international
transactions with its Associated Enterprises (AE):
Ø Provision for Software development and related services
- Rs.12,74,70,626/-
Ø Interest paid
company ostensibly as allocation cost for
joint acquisition of IT infrastructure and software.
3.3-1 The Hon'ble DRP has erred in not appreciating ... Joint acquisition and 801,326,641
Limited development of IT
infrastructure and
software
2. BG India Energy Provision of support 71,045,995
Solutions Private
internet; (ii) providing cloud services; (iii) provision of e-books, movie, music, software and other intangibles through telecommunication networks or internet; (iv) providing data
order of
the CIT(A) for that year.
5. COMPUTER SOFTWARE
On the facts and in the circumstances of the case ... decide afresh the
issue of allowability of computer software expenses of Rs. 52,31,521 on
the basis of certain criteria indicated by him instead
holiday benefits conferred
under the tax holiday benefits as per the Software Technology Park
4
ITA Nos. 6328/Del/2012; 1088/Del/2014 ... company had acquired five companies/business in
the relevant year, namely, Thunaga Software Pvt. Inc. Ltd.,
purchase of business in GSR Systems Inc., purchase
1927/Hyd/2011
TNS India Private Limited
Software Technology Parks of India and provides ITES to its group
companies. For AY. 2007-08, assessee filed ... examination, we find that the DRP, Hyderabad in the case of
Cordys Software India P. ltd., for A.Y. 2008-09 in its directions dated
Ground No.9 and 10 is regarding the disallowance of
cost of software. The Assessing Officer while computing the income of the
assesse disallowed cost ... software treating it as capital expenditure on the
8
ITA Nos.2563/Mum/2007 & ITA.No.2702/MUM/2007&
ITA.No.6299
Software (India) Pvt.Ltd, Pune vs Acit, Cir 4, Pune on 11 September, 2017
आयकर अऩीऱीय अधधकरण "ए" न्यायऩीठ ऩण
ु े में ... 2546/PUN/2012
यनधाारण वषा / Assessment Year : 2008-09
PTC Software (India) Private Limited,
Survey No. 15, Marisoft-II,
Vadgaonsheri, Kalyaninagar,
Pune - 411014
PAN : AABCC1268J
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
