Commissioner Of Income Tax (Ltu) vs M/S Espn Software India Ltd. on 7 November, 2017
Author: S. Ravindra Bhat
Bench: S. Ravindra Bhat , Sanjeev ... 2017
COMMISSIONER OF INCOME TAX (LTU) ..... Appellant
versus
M/S ESPN SOFTWARE INDIA LTD. ..... Respondent
+ ITA 890/2017 & CM No.37958/2017
COMMISSIONER
Limited in the List of Comparables
and excluding M/s. CG-VAK Software and Exports
Limited and Quintegra Solutions Limited ... under section 92A of the Act. The appellant is engaged in
providing software and BPO services to its AE.
3. For the financial year
Commissioner Of Income Tax (Ltu) vs Espn Software India Ltd. on 7 November, 2017
Author: S. Ravindra Bhat
Bench: S. Ravindra Bhat , Sanjeev Sachdeva ... 2017
COMMISSIONER OF INCOME TAX (LTU) ..... Appellant
versus
M/S ESPN SOFTWARE INDIA LTD. ..... Respondent
And connected matters:
+ ITA 890/2017 & CM No.37958
erroneous.
2. The facts are that the assessee is engaged in software
development services to its associated enterprise (AE Group) Genesis
Microchip Inc., US. With ... further submitted that the assessee was
engaged in chip designing and embedded software development.
8. The Court is of the opinion that the arguments
theallocation key (the expenses towards
manpower employed).
2. The assessee is a software development firm which was
engaged inter alia in international transactions that called ... clearly erred in changing the allocation key
of the appellant. Software Development is mainly man
power driven. Therefore, the allocation key, namely the
man power
basis that it had engaged itself in processing and
providing software development and consultancy and engineering
services/web development services. The reasons for execution were ... therefore upheld. The assessee was aggrieved by the inclusion of
Accentia a Software Development Company. The Revenue is
aggrieved by the exclusion of Accentia from
assessee argued that this
Court's judgment in Virtual Software (supra) has been accepted by most
High Courts, i.e. Gujarat High Court, Karnataka
