Deputy Commissioner Of Income-Tax,, vs Tibco Software India Pvt. Ltd.,, Pune on 31 January
software developer whereas Thirdware Solutions
Ltd. is engaged in the business of sale-cum-licence of software
which is available from the audited accounts ... Sale of Licence 22,237,588 3,916,427
Software Services 89,177,023 76,724,371
Export from SEZ unit
software developer whereas Thirdware Solutions Ltd. is engaged in the
business of sale-cum-licence of software which is available from the audited
accounts ... Sale of Licence 22,237,588 3,916,427
Software Services 89,177,023 76,724,371
Export from SEZ unit
engaged in development of own software-
PAPA and has incurred expenses towards import of software service,
evidencing outsourcing of software services unlike the Applicant company ... company observed as under:
"The audited report of the company reveals that company is mainly
engaged in software development. The majority of income
software developer whereas Thirdware Solutions Ltd. is
engaged in the business of sale-cum-licence of software which is
available from the audited accounts ... Sale of Licence 22,237,588 3,916,427
Software Services 89,177,023 76,724,371
Export from SEZ unit
software developer whereas Thirdware Solutions Ltd. is engaged in the
business of sale-cum-licence of software which is available from the
audited accounts ... Sale of Licence 22,237,588 3,916,427
Software Services 89,177,023 76,724,371
Export from SEZ unit
resources deployed on various projects executed for
the AE under provision of software services segment called
30
ITA No.692/PUN/2022
M/s.Persistent ... expenses.
G&A expenses are general in nature like Legal, Audit, HR,
Corporate Planning, Finance, Communications cost, Cost of
Laptop computers used, etc. Therefore
which cropped up lately after new audits by
writing that: "We observe a worrying profusion of software
development at Grupo Antolin plants worldwide. These
further states that "we are in process of clearing Formal Q-
audit and securing VW polo business". This was responded by the
assessee ... which cropped up lately after new audits by writing
that: "We observe a worrying profusion of software development at
Grupo Antolin plants worldwide. These
assessee
is a wholly owned subsidiary of Approva, US. It provides
Software Development Services and Quality Assurance (Testing)
Services to its Associated Enterprises ... return was accompanied by the
Audit Report in Form No.3CEB detailing its international
transaction of providing software services. The assessee received
revenue