foreign software suppliers for
purchase of shrink wrapped software--What is granted under the licence is
only a licence to use the software for internal ... cannot rent, lease, loan, sell or otherwise distribute
the software, documentation or any derivative works based upon the software
or documentation in whole
other format or language or otherwise, translate, or create
derivative works from the Software; (ii) rent, lease, timeshare or otherwise grant
access to the Software ... Software to any third party; or (iii) merge the Software with other software; (iv)
reverse engineer, decompile, disassemble, or otherwise attempt to derive the source
thereon. Consequentially the assessee was
also not able to identify the margins derived from AE transactions in its SD and BPO segments
independently. In this ... mutually agreed between the parties
and detailed in the respective work orders format as specified in Appendix A attached hereto
(collectively referred
discernible link between the level of costs incurred and
market price in software as the services are usually compensated on a
man hourly basis which ... simply not available. Thus, it cannot be said that the gross profit
worked out in the case of the comparable is after taking into account
providing software development services. The contracts entered with customers also
mention the expected standard of services to be provided for software development work ... course of the contract negotiation and mapping of the scope of work, the customer is fully aware of the
underlying delivery mechanism, since technical capabilities
M/S Philips India Ltd., Kolkata vs Dcit, Cir-12(2), Kolkata, Kolkata on 15
Limited has to be excluded as this
company has discontinued its software development services since December, 2010
and drew our attention to page ... 2473/Kol/2017
Assessment Year: 2013-14
M/s. Atlas Healthcare Software India Pvt. Ltd.
5. He also submitted that Zylog Systems (India) Limited
from software development and on line recruitment
services was Rs.1,18,55,867/-. Thus the software development and online recruitment
service income worked ... Appeals) erred in directing the AO to re-compute the profits derived by the
assessee in respect of its EOU Unit in conformity with directions
M/S Labvantage Solutions Pvt. Ltd., ... vs Assessee on 19 October, 2016
1
ITA No
providing
software development services. The contracts entered with customers also mention the
expected standard of services to be provided for software development work ... course of the contract negotiation and mapping of the scope of work, the
customer is fully aware of the underlying delivery mechanism, since technical capabilities
