software expenses. The details of software expenses are as
under:-
Purchase of services for AD manager software Rs.3,00,000
Purchase of antivirus software ... prevented from modifying or duplicating the
software. It could not decompile or disassemble
the software. No derivative works could be
created. The appellant was permitted
The Dcit,(Osd)-1, Circle-4,, ... vs Midvalley Healthcare Services ... on 11 March, 2021
आयकर
same cannot be said to be income derived from export turnover of article or
thing or computer software. The misc. income which is consisting ... working out the deduction u/s 10A it has to
be the receipt derived from the exports of article or things or computer
software
software of 13.11 crores, the outsourcing billing was
11
Rs.1.36 crores. A software product, contains within its numerous sub software
programmes which ... exported computer
software and the profits on which deduction has been claimed is derived
from the unit/undertaking. If part of the work has been
computer software to its AE outside India cannot be regarded as profits &
gains derived by the assessee from the export of computer software
outside ... even on revenue derived by
developing software onsite by sub-contracting the work of software
development to its AE outside India. Since the assessee
purposes of sub-section (1), the profits derived from export of articles or things or computer software shall be the amount which bears ... whole business.
12. It is clear that the profits derived from export of Computer Software for the purposes of Section 10A(1) of the said
software. It is onl y on-site work at USA done b y the
assessee for developing software. "On-site work" would include ... hereby declared that the profits
and gains derived from on-site development of computer software
(including services for development of software) outside India,
shall
compounds but for entire research work including
intellectual property embedded therein and unless
export benefits were derived from manufacture of
articles or things, an assessee ... only exception was with regard to computer software.
7
6. It is contended that the work done by the
assessee is not different from works
taken on rent by
way of sub lease and derive rental income. The work stations already existed
and were meant for use by the Assessee ... approached WNS for a work
space and WNS hereby agrees to allow CTS to carryout their business
of software development from the office space
work out
the profits derived from the export of article or thing or computer
software for the purpose of allowing deduction under
