software for the Alcatel Lucent group of
companies. ADIPL provides services in respect of software
implementation, customization and maintenance. ALTIPL is also a
software development ... audit).
47. The company provides application development, software
development, product development, software testing etc.
According to the web site of the assessee
48. Our software
software for the Alcatel Lucent group of
companies. ADIPL provides services in respect of software
implementation, customization and maintenance. ALTIPL is also a
software development ... audit).
47. The company provides application development, software
development, product development, software testing etc.
According to the web site of the assessee
48. Our software
Companies Act, 1956
and is engaged in the business of software development and related
services. The Assessee has six units, which includes three units, that ... provide software services,
which were in the nature of developing and supplying customized
software and related software services during the financial year
explanations furnished by the
Assessee, the AO concluded that the software development centres of OIPL
located at Hyderabad and Bangalore constituted the Assessee ... nature of royalty from Global Deals‖; and
―Profit from Software Development in India‖. The Assessing Officer
noticed that in several cases the associate concerns
enclosed as Annexure 5 of this section.
(d) Software Development
ATS Inc. provides software development services with
respect to various software applications used ... AIGSPL.
The AO had also reasoned that since the petitioner provided software
development services with respect to the petitioner's software application
used
human resources consulting services, payroll processing, business
process outsourcing, and software development services. It had, during
the relevant AY, rendered such services ... well as unrelated
parties. However, the Assessee had confined rendering of software
development services, business process outsourcing services to its AEs.
Signature Not Verified
Digitally
respect of the international transactions in relation to the software
development segments.
3. The assessee had furnished its transfer pricing study before the
Transfer Pricing ... assessee. However, the TPO adopted seven additional comparables
entities in the software development services segment and excluded certain
other comparables, for determining the mean
business of software related services such
ITA Nos. 607 & 608 of 2015 Page 2 of 9
as software design and development. The business ... conducted at the
Software Development Centre („SDC‟) at Chennai for which the Assessee
claimed exemption under Section 10A of the Act. Apart from this
work
was awarded for development, implementation and maintenance of e-
enabled system for registration, examination of answer sheets, development
of software for facilities management services ... architect and not competent to undertake the assignment
of software development, which fact has not been disputed by the
Petitioner.
16. The respondent further contended
Court rejected the contention that the
appellants were collective owners of the software. The Court held that
Signature Not Verified
Digitally Signed
By:Dushyant Rawal ... only world famous in
their respective software development domains but
are the largest and the biggest software companies in
the world. The global presence
