including code division
multiple access [CDMA] technology and manufactures
semiconductors and provides software for wireless
communications, especially in mobile devices. Petitioner
5
claims that ... have paid certain percentage of royalty
to Qualcomm and Beijing Xiaomi Mobile Software Co.,
Ltd., which is as follows:
Payment made to Beijing
Payment made
quash condition of
passing AUTO-CAD course from the authorized institute of software provider
as per Appendix 'B' of Haryana Public Health Engineering ... qualifications of passing AUTO-CAD course
from centre authorized by the software providers. Reference has also been made
to the Government decision dated 25.08.2014 whereby
holding that
the income earned by the Appellant from distributing of computer
software in India was royalty for the purposes of Section ... four categories:
i) The first category deals with cases in which computer
software is purchased directly by an end-user, resident in
India, from
Disallowance of expenditure incurred towards purchase of
application software
vi) Disallowance of provision made towards leave availment
under section
Agilent
Technologies, Inc. The assessee is engaged in the provision of Software
Development (IT) services and Information Technologies Enabled Services
(ITES). It filed its return ... under:-
2
ITA No.6047/Del/2012
2.2 So far as the Software Development Segment is concerned, the TPO noted
that the tax payer
Adani Petronet( Dahej) Port Pvt. Ltd.,, ... vs The Dy.Commissioner Of Income Tax, ... on 31
assessee is a private limited
company operating in two business segments viz., Software
development services and IT enabled services and the assessee is
Page ... capitaline databases to search for the
comparables and identified 11 comparables under Software
Development Services and arrived at the arithmetic mean of
13.49% as against
also making available
its technology in the form of sophisticated equipments and
software etc. The learned CIT(A) has held that : "in order ... involved and to whom the appellant is committed to
providing the requisite software and equipment". The learned
CIT(A) has also accentuated
Reimbursement of INR 1,83.92,376/-.
received on account of SAP software and
Microsoft license fees taxed as Royalty under
section ... facts
and circumstances of the case and in law by
concluding that software license fees, i.e., fees paid
in lieu of SAP Software License
Concerto Software And Systems Pvt Ltd, ... vs Dy Commissioner Of Income Tax, Circle ... on 10 August ... 1854/Mum/2022
Assessment year: 2018-19
Concerto Software and Systems Pvt. Ltd. .............................. Appellant
Unit No. 311/312/313, Building 2, Sector-1,
Millennium Business
