program.
4 Erred in holding that the AdWords program is complex computer software,
the right to use has been granted to the Appellant without appreciating ... program
without parting with the copyright, thus granting licence to use the software
without appreciating the fact that the Appellant is only involved in marketing
Aztec Software And Technology Service ... vs Acit on 12 July, 2007
Equivalent citations: [2007]107ITD141(BANG), [2007]294ITR32(BANG)
ORDER
Vimal Gandhi, President ... Indian company engaged in the business of development and export of software. The assessee was also entitled to deduction Under Section 10A of the Income
business of distribution of computer systems, designs and development of computer software. The assessee filed return of income for the present assessment year returning income ... export turnover. The assessee has no other operations apart from providing software technical services. The learned departmental Representative also relied on the order
Imaging Inc.(EFI group), USA. It is engaged
in the business of software development and marketing support
services to Associated Enterprises (AEs).
3. Return ... following international
transactions with its Associated Enterprises (AE):
Ø Provision for Software development and related services
- Rs.12,74,70,626/-
Ø Interest paid
assessee is engaged in different types of business activities,
viz., software development services and IT services; manufacture of
Vanaspati/Hydro generated oils; toilet soaps; lighting ... generated from non-STPI/non-SEZ undertakings.
STPI refers to "Software Technology Park" and SEZ refers to "Special
Economic Zone". This
profits derived from its Software Technology Parks of India (STPI)
registered unit. Sec.10A(4) provides the methodology of computation of
deduction ... that the profits derived from
export of articles or things or computer software shall be the amount which
bears to the profits of the business
undertaking from the export of articles or things or computer software is required to be allowed from the total income of the assessee ... submitted that the company operates the following 3 divisions:
(a) Software service division
(b) Product service division
(c) Systems service division
7. The software service
Transfer Pricing Study for the technical support services segment such as
Akshay Software Technologies Ltd and Evoke Technologies Pvt. Ltd. without
considering the functional ... reason that it does not have segmental results pertaining
to Software Development Service without appreciating that the company qualify all
the qualitative and quantitative filters
Sharp Software Development India ... vs Dcit, Bangalore on 9 December, 2016
IT(TP)A.1102/Bang/2011 Page - 1
IN THE INCOME TAX APPELLATE TRIBUNAL ... 1102/Bang/2011
(Assessment Year : 2007-08)
Sharp Software Development India P. Ltd,
Unit 5, Level 3, Innovator, International Tech Park,
Whitefield Road, Bengaluru
Electronics Company Ltd., Korea, engaged in the development, manufacture and export of software for use by its parent company, i.e., Samsung Electronics ... Korea. The assessee develops various kinds of software for telecommunication system, for office appliances, for computer systems and for mobile devices, etc. The software developed
