Aurigo Software Technologies Private ... vs Income Tax Officer, Ward-1(1)(1), ... on 3 February, 2022
IN THE INCOME TAX APPELLATE TRIBUNAL ... Bang/2021
Assessment Year : 2016-17
M/s. Aurigo Software Technologies Private Limited, Vs. ITO,
Ajmera Aditya Summit, No.3D1, Ground Floor, Ward
relief
granted in respect of addition relating to transfer pricing
adjustment in Software development services. Besides the same,
the revenue has also raised a ground ... challenging the direction given
by Ld CIT(A) to grant depreciation on software purchases.
4. In the cross objection and additional Cross objection, the
assessee
Taxability of revenue from sale of software
2.1 That on the facts and in the circumstances of the case ... earned by the Appellant from sale of Microsoft
Retail Software Products to distributors in India is taxable as
"Royalty" ignoring the fact that
sole owner of intellectual property rights vested in
Microsoft Software. It has granted exclusive license to manufacture and distribute
Microsoft products ... assessee):
• exclusive license to manufacture and distribute Microsoft retail software
products directly to retailers or to MS Corp or to subsidiaries of MS Corp
7819/Del/2017
associated enterprise in respect of rendering of software
development services to its associated enterprise and
thereby resulting in the enhancement of returned ... Melstar Information Technologies Ltd.
ii. V & J Softech Ltd.
iii. FSL Software Technologies 'Ltd
7. The Ld. TPO has erred in computing
Geometric Software Solutins Co. Ltd ( ... vs Addl Cit Rg 10(2), Mumbai on 29 July, 2022
Page | 1
ITA no.6219/Mum/2010
Geometric software ... 6219/Mum/2010
( Assessment Year 2005-06)
M/s Geometric Software
The ACIT
Solutions Company Ltd.
W ard 10(2),
[ Now merged with HCL
Room
income by the Appellant.
2. Taxability of revenue from sale of software
2.1 That on the facts and in the circumstances of the case ... erred in holding that the revenue earned and received from sale of
software by MRSC amounting to INR 38,32,90,74,884 is taxable
Application u/s 158A filed by the Appellant.
Grounds on taxability of Software License:
3. That on facts ... contentions of the Appellant that reimbursement of
actual costs relating to Software License and maintenance charges
amounting
National Association Of Software And ... vs Ddit (E), Inv. Circle-Ii, New Delhi on 17 March, 2022
IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH ... 7787/Del/2018 : Asstt. Year : 2007-08
National Association of Software & Vs DDIT(Exemption) Inv.,
Service Companies (NASSCOM), Circle-II,
Ground Floor, IETE Building
present appeal
is whether the Revenue earned from sale/distribution of software is
chargeable to tax in India as Royalty under Article 12 of India ... Ireland. Assessee is basically engaged in the
business of sale of software and hardware and provision of support
services. During the year under consideration
