same has been sought in this Writ Petition.
4. The definition of technology' in the Research and Development Cess Act, 1986 , is extracted below ... that judgment which are extracted below:-
8. To my mind, the definition of technology clearly demonstrates that the foreign collaboration itself must be distinct from
maintenance
of software. These activities are covered only by the definition of
Information Technology Software Service and cannot be brought within the
definition of MMRS ... total convergence between the technical literature on software
and the definition of information technology software service given
under Section 65(105)(zzzze) of the Finance
hold that in view of definition of 'royalty', what was
15
ITA No.1433/PUN/2014
Tata Technologies Ltd.
being transferred was right ... scientific
20
ITA No.1433/PUN/2014
Tata Technologies Ltd.
work has referred to in the definition of 'royalty' under DTAA, obviously includes
sourced to HSCL was in the nature of Information Technology
Service. The definition of BAS has excluded Information Technology
Services, through the above Explanation. Consequently ... computer software;
(b) "properties" includes information technology software‟"
18. From the above definition it is evident that the service
appended at
the end of the definition in Section 65 (19) for BAS explains
what constitutes „Information Technology Service‟. One of
the activities subsumed within ... sourced to HSCL was in the nature of
Information Technology Service. The definition of BAS has
excluded Information Technology Services, through the
above Explanation. Consequently
through its two units
situated in Software Technology Park, Gurgaon (Now
Gurugram) which falls under the definition of the Section
Jcit, Rang-2, Kota vs Chambal Fertilisers And Chemicals ... on 17 October, 2018
vk;dj
commerce website
automatically come under the definition of intermediary? As per the
Information Technology Act, 2000 (hereinafter, ' IT Act ') an `intermediary
M/S.Us Technology Resources P. Ltd, ... vs The Dcit, Trivandrum on 23 May, 2018
assistance or
use of information technology. It was also submitted that
this company does not satisfy the definition of ITES as
contained in Rule 10TA
