export of
computer software where the business entity provides
technical services outside India in connection with
developments or production of computer software.
Hence, the aspect ... Section 10A under the head
of 'Profits' derived from export of computer software or
under the head of 'rendering technical services outside
export of
computer software where the business entity provides
technical services outside India in connection with
developments or production of computer software.
Hence, the aspect ... Section 10A under the head
of 'Profits' derived from export of computer software or
under the head of 'rendering technical services outside
export of
computer software where the business entity provides
technical services outside India in connection with
developments or production of computer software.
Hence, the aspect ... Section 10A under the head
of 'Profits' derived from export of computer software or
under the head of 'rendering technical services outside
clients located outside
India. Due to the peculiar nature of software
development work, it has been suggested that
such deputation of Technical Manpower
abroad should ... profits and gains derived from 'services
for development of software' outside India
would also be deemed as profits derived from
export
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
Ms (X) vs Internal Complaints Committee on 30 September, 2024
Author: M.G.S. Kamal
other person working for and
on behalf of the Defendants, from infringing in any
manner the copyright in the literary work subsisting in
the documents ... flow charts, algorithms,
coding sheets, source code of the Plaintiff's softwares,
etc. and from reproducing and/or substantially
reproducing and/or copying
export of computer software where
the business entity provides technical services outside India in
connection with developments or production of computer
software. Hence, the aspect ... Section 10A under the head of 'Profits' derived from
37
export of computer software or under the head of 'rendering
technical services
obligations under the Agreement and rendered
the support for acquisition of hardware, software service
networking, running a data center, implementation and training in
data migration ... work performed by PIPL.
6. Certain disputes arose between the parties. PIPL claimed
that despite its opposition, National Commodities Derivatives
Exchange [NCDEX] was inducted
India attributable to its activities
of export out of India of computer software or its
transmission from India to a place outside India ... outside India in
7
connection with the development or production of
computer software, were entitled to claim a deduction in
computing the total income
