which public are substantially interested and is engaged in the
business of Software Product Development. It filed its return of
income on 01.12.20013 declaring loss ... objects clause to provide for
development and marketing of health-care related software
services. During the year under consideration, the assessee
centre support services, back-office support services and
offshore development support services [Software Development ("SWD")] to its
associated enterprises ... assessee. It is a fact that an
ITES company uses software as a platform to deliver services. Such
software could either tip indigenously developed
Fees for Included Services [FIS]; and
(ii) Secondly, taxation of software reimbursements of Rs.
3,53,693/- as Royalty.
3. Representatives were heard at length ... following streams:
(i) Engineering fees Rs. 7,001,452/-
(ii) Reimbursement on software costs Rs. 353,693/-
(iii) Reimbursement of salary & related costs
Kooud Software Private Limited, ... vs Deputy Director Of Income Tax, Cpc-Tds, ... on 25 March, 2022
IN THE INCOME TAX APPELLATE TRIBUNAL ... Bang/2022
Assessment year : 2013-14 & 2014-15
M/s Kooud Software Pvt. Ltd., Vs. The Dy. Director of Income
reinstating comparable namely M/s C G Vak Software
& Exports Ltd. on the ground that it was not a loss making company ... this appeal, Revenue has challenged the inclusion of M/s. CG VAK
Software and Exports Ltd. as a comparable for benchmarking the
international transactions entered
books of accounts and stock as per register maintained through a
software application i.e. "ACME Software". During the course of
survey proceedings ... stock
3
ITA No.1001/PUN/2017
shown in the ACEM Software. The factual matrix leading to the
above addition is as under :
An amount
Software Communications Pvt. Ltd, ... vs Acit Cir 16(1) , Mumbai on 22 April, 2022
ITA No.2024/Mum/2021 A.Y.2013 ... Software Communications Pvt. Ltd. Vs. ACIT, Circle 16(1)
THE INCOME TAX APPELLATE TRIBUNAL
"F" BENCH, MUMBAI
BEFORE SHRI VIKAS AWASTHY, JUDICIAL MEMBER
Arcserve India Software Solution Pvt. ... vs Acit Circle -3(1), New Delhi on 27 June, 2022
IN THE INCOME TAX APPELLATE TRIBUNAL
DELHI BENCH ... MEMBER
ITA No. 5244/Del/2019
Assessment Year: 2015-16
Arcserve India Software Versus ACIT,
Solutions Pvt. Ltd., 1568, Circle-3(1),
2nd Floor, Kashmere
income - Rs.4,25,84,960; &
ii) income from sale of software as royalty to be taxed on
gross basis ... offshore supply of
equipments by apportioning 70% towards hardware and 30% towards
software embedded in the hardware. He submitted, while the amount
Ashish Poddar vs Income Tax Officer Ward 54(1) & Anr. on 27 July, 2022
