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
COMPETITION COMMISSION OF INDIA
Case No. 52 of 2013
In Re:
Financial Software and Systems Private Limited Informant
And
M/s ACI Worldwide Solutions Private ... Panda, Advocate
Ms. Ela Bali, Advocate
Final Order
1. M/s Financial Software and Systems Private Limited (hereinafter, the
'Informant
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
engaged in the business of design and development of
customized software applications. Apart from that, it also provided
technical support services during the relevant year ... India. The assessee reported four international
transactions including "Provision of Software Development" with
transacted value of Rs. 20,72,25,235/-, which
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
direction of the learned CIT(A) in allowing the claim of software development expenses amounting to Rs. 6,76,000.
3.1 The learned senior Departmental ... nature of the accounts of the assessee. He also submitted that its software programs if prepared then the same will last at least
company ostensibly as allocation cost for
joint acquisition of IT infrastructure and software.
3.3-1 The Hon'ble DRP has erred in not appreciating ... Joint acquisition and 801,326,641
Limited development of IT
infrastructure and
software
2. BG India Energy Provision of support 71,045,995
Solutions Private
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
order of
the CIT(A) for that year.
5. COMPUTER SOFTWARE
On the facts and in the circumstances of the case ... decide afresh the
issue of allowability of computer software expenses of Rs. 52,31,521 on
the basis of certain criteria indicated by him instead