paid by the concerned persons resident in India to non-
resident, foreign software suppliers, amounted to royalty and as this
was so, the same constituted ... four categories:
i) The first category deals with cases in which computer software is
purchased directly by an end-user, resident in India, from
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
engaged in the
business of development and export of computer softwares and
rendering technical services.
(b) The Respondent has shown gross income from business ... Assessing Officer, vide order dated 28.12.2006, held
that the software development charges, as claimed by the
Respondent, are nothing but in the nature of expenses
undertaking from the export of articles or things
or computer software for a period of ten consecutive assessment
years commencing from the assessment year relevant ... profits derived from the export of articles or things or
computer software shall be computed. Sub section (4) provides as
follows :
"For the purposes
have
to confine itself to the question as to whether the concerned software would
come within the purview of "goods". In the Constitution ... held that a sale of
a computer system, comprising both hardware and
software, was a sale of "goods" within the
meaning both
SAMSUNG ELECTRONICS LTD,
INDIA SOFTWARE OPERATIONS "
LEVEL em 1{'.ND_7TH, _ '
P1?I£*STTGE»»N:ERIDLAN ... IVLV. SeShaChB121_, AdIf.}__ ' . 1
And :
M/ S. RAFFLES SOFTWARE 2;' I O'
7?" FLOOR, No.12}, I
DICKENSON ROAD, '
BANGALORE
allowed holding that no central excise duty
is payable on a software loaded in a hardware, i.e., computer.
FACTS:
The Respondent is a company ... WIPRO, the Respondent, on orders received
from the customers load operational softwares. While calculating the amount
of central excise payable thereupon, it would deduct
Commr.Of Income Tax-V,New Delhi vs M/S Oracle Software India Ltd on 13 January, 2010
Author: S.H. Kapadia
Bench: Surinder Singh ... Income Tax-V, New Delhi ... Appellant(s)
versus
M/s. Oracle Software India Ltd. ... Respondent(s)
with
C.A.No.238/2010
category
wherever it is likely to reach earlier, as per the CMIS software.
Further liberty is granted to the parties to mention the main
matter ... category
wherever it is likely to reach earlier, as per the CMIS software.
Further liberty is granted to the parties to mention the main
matter
Pune vs Ptc Software (I) Pvt Ltd on 14 July, 2014
À ITEM NO.28 COURT NO.4 SECTION IIIA ... Court Of Bombay)
C.I.T-II,PUNE Petitioner(s)
VERSUS
PTC SOFTWARE (I) PVT LTD Respondent(s)
(With appln.(s) for c/delay