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“computer software”

Chapter III - Incomes Not IncludedSection 10BSection 10B Explanation 2 / Section 80HHF951 judgments

The decision most relied on for computer software is Engineering Analysis Centre of Excellence (P) Ltd. v. CIT (432 ITR 471), cited in 914 judgments on BharatTax.

Leading authorities on computer software

Engineering Analysis Centre of Excellence (P) Ltd. v. CIT
432 ITR 471 · 2021 · Supreme Court
914
citing judgments

Payments for the supply or use of computer software, where there is no transfer of copyright but only a right to use the copyrighted product, are generally considered business profits and not 'royalty' or 'fees for technical services' under the Income Tax Act, 1961 or relevant DTAAs. This principle also applies to transponder fees, which are not taxable as royalty.

CIT v. Samsung Electronics Ltd.
345 ITR 494 · 2012 · High Court
461
citing judgments

Payments by Indian residents to non-resident foreign software suppliers for software are considered royalty, constituting income deemed to accrue in India under section 9(1)(v), thereby requiring tax deduction at source under section 195.

DIT v. Infrasoft Ltd.
39 Taxmann.com 88 · 2013 · High Court
269
citing judgments

Payments for the use of copyrighted software, without the transfer of any rights in the underlying copyright itself, do not constitute 'royalty' under the Income-tax Act or tax treaties. Such payments are often treated as business income, taxable only if a permanent establishment exists.

III v. HCL Technologies Ltd.
93 Taxmann.com 33 · 2018 · Supreme Court
245
citing judgments

When computing the deduction available under Section 10A of the Income-tax Act, communication expenses must be excluded from the total turnover for the purpose of calculating the eligible relief.

CIT v. Synopsis International Old Ltd.
212 Taxmann 454 · 2013 · High Court
177
citing judgments

Payments for computer software are treated as royalty income under Section 9(1)(vi) of the Income-tax Act, particularly concerning the expanded definition provided by Explanation 2 and Explanation 4.

CIT v. Asahi India Safety Glass Ltd.
346 ITR 329 · 2012 · High Court
129
citing judgments

Expenses incurred for software license purchase, development of miscellaneous software, and maintenance of websites are considered revenue in nature. Such expenses are deductible in the year they are incurred.

Amway India Enterprises v. DCIT
111 ITD 112 · 2008 · ITAT
127
citing judgments

Depreciation is allowable on computer software, including software licenses, at the rate of 60%.

Kotak Mahindra Primus Ltd. v. DDIT
11 SOT 578 · 2007 · ITAT
99
citing judgments

Payments for data processing services using a mainframe computer and specialized software are not taxable as fees for the use of equipment if the Indian entity lacks independent rights or physical access to use the computer or software.

Judgments citing computer software

Joint Commissioner of Income Tax (Ltu), Bangalore vs. M/S Dell International Services India Private Limited, Bangalore

In the result, the appeals of the assessee and the revenue are partly allowed

ITA 844/BANG/2017[2012-13]Status: DisposedITAT Bangalore14 Nov 2022AY 2012-13

Bench: Smt. Beena Pillai & Ms. Padmavathy Sit(Tp)A No.844/Bang/2017 Assessment Year : 2012-13 The Joint Vs. M/S.Dell International Services India Commissioner Of Private Limited, Income Tax, Ltu, (For The Merged Entity Dell India Bangalore. Private Limited), No.12/1, 12/2A, 13/1A, Divyashree Gardens, Challagutta Village, Varthur Hobli, Bangalore – 560 071. Pan : Aaach1925Q Appellant Respondent It(Tp)A No.932/Bang/2017 Assessment Year : 2012-13 M/S.Dell International Services Vs. The Joint Commissioner India Private Limited, Of Income Tax, Ltu, (For The Merged Entity Dell India Bangalore. Private Limited), Bangalore – 560 071. Pan : Aaach1925Q Appellant Respondent Revenue By : Shri Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru. Assessee By : Shri T. Suryanarayana, Advocate Date Of Hearing : 07.11.2022 Date Of Pronouncement : 14.11.2022

For Appellant: Shri T. Suryanarayana, AdvocateFor Respondent: Shri
Section 143(2)Section 92C

Chennai unit was formed by splitting up or reconstruction of a business already in existence and; (iii) the unit did not export any computer software. 46. For the year under consideration the AO followed the order for AY 2010-11, and disallowed the claim of deduction u/s.10AA by stating that ... outside India or expenses, if any, incurred in foreign exchange in IT(TP)A Nos.844 & 932/Bang/2017 Page 40 of 53 rendering of services (including computer software) outside India. From the definition it is clear that for the purpose claiming the deduction u/s.10AA, the proceeds of the export turnover should have

Fireeye Cybersecurity Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee stands partly allowed

ITA 292/BANG/2021[2016-17]Status: DisposedITAT Bangalore10 Nov 2022AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 292/Bang/2021 Assessment Year : 2016-17 M/S. Mandiant Cyber Security Pvt. Ltd. (Formerly Known As Fireeye The Deputy Cybersecurity Pvt. Commissioner Of Ltd.), Income Tax, No. 5, Front Wing Circle – 3(1)(1), Salarpuria Infinity, Vs. Bengaluru. 2Nd Floor, Bannerghatta Road, Bengaluru – 560 029. Pan: Aaccf1341A Appellant Respondent : Shri T. Suryanarayana, Assessee By Senior Advocate Revenue By : Shri Vilas Shinde, Cit Dr Date Of Hearing : 26-09-2022 Date Of Pronouncement : 10-11-2022 Order Per Beena Pillaipresent Appeal Arises Out Of Order Passed By National E- Assessment Centre, Delhi Dated 30/04/2021 On Following Revised Grounds Of Appeal:

For Respondent: Shri T. Suryanarayana

specification provided by FireEye US. Verification or software testing is the process used to help identify the correctness, completeness, security and quality of developed computer software. Various testing methodologies and tools are/ or be used in this process. This step helps to uncover errors and ensure that defined input will ... Computer equipments — appliances 34,399,073 Furniture and fixtures 5,894,012 Leasehold improvements 57,607,801 Office equipments 44,773,000 Computer software 953,500 Total 285,155,291 Summary and Economic Characterization Based on the functional and risk analysis relating to IT services, ITeS and MSS rendered

M/S. Silverline Industries Ltd., Mumbai vs. ITO - 3(3)(2), Mumbai

In the result, the appeal filed by the assessee is treated as allowed for statistical purposes

ITA 1738/MUM/2020[2003-04]Status: DisposedITAT Mumbai08 Nov 2022AY 2003-04

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadalem/S Silverline Industries Vs. Ito – 3(3)(2) Ltd.,Unit No. 121, Sdf Iv Mumbai – 400021. Seepz Andheri (E), Mumbai – 400096. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aaacs7365M Appellant .. Respondent Appellant By : None Respondent By : Shri Suresh Periasamy.Dr Date Of Hearing 13.10.2022 Date Of Pronouncement 17.10.2022 आदेश / O R D E R Per Pavan Kumar Gadale, Jm: The Assessee Has Filed The Appeal Against The Order Of The Commissioner Of Income Tax (Appeals)-18, Mumbai Passed U/S 271(1)(C) & 250 Of The Act. The Assessee Has Raised Grounds Of Appeal Challenging The Levy Of Penalty U/Sec 271(1)(C) Of The Act.

For Appellant: NoneFor Respondent: Shri Suresh Periasamy.DR
Section 143(1)Section 143(2)Section 144Section 271(1)(C)Section 271(1)(c)

material information available on record. 3. The brief facts of the case are that the assessee company is engaged in the business of computer software development and export local sales of software including services and Hi-tech training. The assessee has filed the return of income

Dy CIT, Circle-8(2)(1), Mumbai vs. M/S Siemens Technology & Services P. Ltd ( Formerly Known As Siemens Information Systems Ltd.), Mumbai

In the result, both the appeals of the Revenue are dismissed

ITA 287/MUM/2021[2004-05]Status: DisposedITAT Mumbai02 Nov 2022AY 2004-05
Section 10ASection 143(2)Section 143(3)

existence, they are not formed by a transfer of machinery or plant previously used for any purpose and they have begun manufacture/production of computer software in the software technology Park after first April 1994. In view of these facts, I'm of the opinion that the AO was not justified

Dy CIT, Circle-8(2)(1), Mumbai vs. M/S Siemens Technology & Services P. Ltd ( Formerly Known As Siemens Information Systems Ltd.), Mumbai

In the result, both the appeals of the Revenue are dismissed

ITA 286/MUM/2021[2003-04]Status: DisposedITAT Mumbai02 Nov 2022AY 2003-04
Section 10ASection 143(2)Section 143(3)

existence, they are not formed by a transfer of machinery or plant previously used for any purpose and they have begun manufacture/production of computer software in the software technology Park after first April 1994. In view of these facts, I'm of the opinion that the AO was not justified

Aker Powergas P. Ltd, Mumbai vs. DCIT RG 15(1)(1), Mumbai

ITA 2213/MUM/2017[2012-13]Status: DisposedITAT Mumbai31 Oct 2022AY 2012-13

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2012-13

For Appellant: Shri Ketan Ved, A.RFor Respondent: Ms. Samruddhi Dhananjay Hande, D.R
Section 143(3)Section 144BSection 144C(3)Section 92C

Indian and international jurisprudence for justification on payment for availing management services. 2. Disallowance of software expenses 2.1 The learned DCIT/DRP erred in disallowing computer software expenses of Rs.14,74,19,626 which are revenue expenses, by treating the same as capital in nature. 2.2 The learned DCIT/DRP erred ... aforesaid grounds 1.1 to 1.10 are determined in favour of the assessee for statistical purposes. Corporate Grounds: Ground No.2 11. TPO/DRP have disallowed computer software expenses of Rs.14,74,19,626/- by treating the same as capital in nature, which are under challenge before the Tribunal

M/S Honeywell Technology Solutions Lab Private Limited, Bangalore vs. Joint Commissioner of Income Tax Special Range-3, Bangalore

ITA 2891/BANG/2018[2013-14]Status: DisposedITAT Bangalore31 Oct 2022AY 2013-14

Bench: Shri Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2013-14

For Appellant: Smt. Shreya Loyalaka, AdvocateFor Respondent: Shri Dilip Jr. Standing Counsel for Dept. (DR)
Section 192Section 195Section 40Section 80JSection 9(1)(vii)

assessee is as under 1. Rs. 27,75,50,408/- for AMC FOR Computer License. 2. Rs. 20,18,64,979/- for purchase of computer software ( including Hardware) 13. The AO noted that the TDS should be made on the entire payments of AMC but assessee did not deduct ... license, transfer, reverse engineer, modify or reproduce the software and therefore, held that since the payers only get a right to use computer software and not any of the rights conferred on the owner of a copyright under the Indian Copyright Page 13 of 30 Act, 1957, the payments made

M/S. Mindtree Limited (Successor in Interest to M/S. Aztecsoft Limited), Bengaluru vs. The Joint Commissioner of Income Tax (OSD), Central Circle-1(3), Bangalore

In the result, the appeal filed by the assessee stands allowed on Ground nos

ITA 269/BANG/2021[2006-07]Status: DisposedITAT Bangalore28 Oct 2022AY 2006-07
For Respondent: Shri Tata Krishna
Section 144CSection 147Section 148Section 150(1)Section 153Section 153(5)Section 92CSection 92C(3)Section 92D

Officer are not justified in failing to appreciate that when the telecommunications expenses incurred by Appellant were not attributable to the delivery of the computer software outside India, no exclusion could have been made from the 'export turnover' of the Appellant. 6.6. Without prejudice to the above, the question

M/.S Synamedia India Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 6(1)(2), Bangalore

In the result, the appeal filed by assessee stands allowed in respect of the issues argued and considered hereinabove

ITA 2595/BANG/2019[2015-16]Status: DisposedITAT Bangalore21 Oct 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(Tp)A No. 2595/Bang/2019 Assessment Year : 2015-16 M/S. Synamedia India Pvt. Ltd., Block 9A & 9B, The Deputy Pritech Park, Commissioner Of Survey No. 51-64/4, Income Tax, Sarjapur Outer Ring Circle – 6(1)(2), Road, Bengaluru. Vs. Bellandur Village, Bengaluru – 560 103. Pan: Aaccn1140K Appellant Respondent Assessee By : Shri Ankur Pai, Advocate : Shri Praveen Karanth, Revenue By Cit-Dr Date Of Hearing : 28-07-2022 Date Of Pronouncement : 21-10-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against The Final Assessment Order Dated 29/10/2019 Passed By The Ld.Dcit, Circle – 6(1)(2), Bangalore For A.Y. 2014-15 On Following Grounds Of Appeal:

For Appellant: Shri Ankur Pai, Advocate
Section 143(2)

information to indicate that the brand has impacted the revenue or profit of the company. The intangibles referred in the Asset Schedule represent the computer software, and business rights and as such does not refer to any IPR or license owned by the said company. Certain developments are under

M/S Google India Private Limited, Bangalore vs. Dy. D.I.T., Bangalore

In the result, the appeals filed by the assessee are allowed

ITA 1516/BANG/2013[2012-13]Status: DisposedITAT Bangalore19 Oct 2022AY 2012-13

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.1513/Bang/2013 : Asst.Year 2009-2010 It(Tp)A No.1514/Bang/2013 : Asst.Year 2010-2011 It(Tp)A No.1515/Bang/2013 : Asst.Year 2011-2012 It(Tp)A No.1516/Bang/2013 : Asst.Year 2012-2013 M/S.Google India Private Limited The Deputy Commissioner Of No.3, Rmz Infinity Tower-E Income-Tax (International V. 4Th Floor, Old Madras Road Taxation), Circle 1(1) Bangalore. Bangalore – 560 016. Pan : Aaccg0527D. (Appellant) (Respondent) Appellant By : Sri.Percy Pardiwala, Sr.Advocate, Sri.Anmol Anand, Advocate, Miss.Priya Tandon, Advocate & Sri.Vinay Mangla, Ca Respondent By : Sri.K.V.Aravind, Standing Counsel Date Of Pronouncement : 19.10.2022 Date Of Hearing : 13.09.2022 O R D E R Per George George K, Jm : These Appeals At The Instance Of The Assessee Were Originally Disposed By The Itat Vide Its Common Order Dated 23.10.2017. On Further Appeal At The Instance Of The Assessee, The Hon’Ble High Court Vide Judgment Dated 17.04.2021 In Ita No.883/2017, 897/2017 To 899/2017, Restored The Matter To The Itat For De Novo Consideration. The Relevant Finding Of The Hon’Ble High Court Reads As Follows:-

For Appellant: Sri.Percy Pardiwala, Sr.Advocate, Sri.Anmol AnandFor Respondent: Sri.K.V.Aravind, Standing Counsel
Section 201Section 201(3)Section 9(1)(vi)

IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES “C”, BANGALORE Before Shri George George K, JM & Ms.Padmavathy S, AM IT

M/S Google India Private Limited, Bangalore vs. Dy. D.I.T., Bangalore

In the result, the appeals filed by the assessee are allowed

ITA 1515/BANG/2013[2011-12]Status: DisposedITAT Bangalore19 Oct 2022AY 2011-12

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.1513/Bang/2013 : Asst.Year 2009-2010 It(Tp)A No.1514/Bang/2013 : Asst.Year 2010-2011 It(Tp)A No.1515/Bang/2013 : Asst.Year 2011-2012 It(Tp)A No.1516/Bang/2013 : Asst.Year 2012-2013 M/S.Google India Private Limited The Deputy Commissioner Of No.3, Rmz Infinity Tower-E Income-Tax (International V. 4Th Floor, Old Madras Road Taxation), Circle 1(1) Bangalore. Bangalore – 560 016. Pan : Aaccg0527D. (Appellant) (Respondent) Appellant By : Sri.Percy Pardiwala, Sr.Advocate, Sri.Anmol Anand, Advocate, Miss.Priya Tandon, Advocate & Sri.Vinay Mangla, Ca Respondent By : Sri.K.V.Aravind, Standing Counsel Date Of Pronouncement : 19.10.2022 Date Of Hearing : 13.09.2022 O R D E R Per George George K, Jm : These Appeals At The Instance Of The Assessee Were Originally Disposed By The Itat Vide Its Common Order Dated 23.10.2017. On Further Appeal At The Instance Of The Assessee, The Hon’Ble High Court Vide Judgment Dated 17.04.2021 In Ita No.883/2017, 897/2017 To 899/2017, Restored The Matter To The Itat For De Novo Consideration. The Relevant Finding Of The Hon’Ble High Court Reads As Follows:-

For Appellant: Sri.Percy Pardiwala, Sr.Advocate, Sri.Anmol AnandFor Respondent: Sri.K.V.Aravind, Standing Counsel
Section 201Section 201(3)Section 9(1)(vi)

IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES “C”, BANGALORE Before Shri George George K, JM & Ms.Padmavathy S, AM IT

M/S Google India Private Limited, Bangalore vs. Dy. D.I.T., Bangalore

In the result, the appeals filed by the assessee are allowed

ITA 1514/BANG/2013[2010-11]Status: DisposedITAT Bangalore19 Oct 2022AY 2010-11

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.1513/Bang/2013 : Asst.Year 2009-2010 It(Tp)A No.1514/Bang/2013 : Asst.Year 2010-2011 It(Tp)A No.1515/Bang/2013 : Asst.Year 2011-2012 It(Tp)A No.1516/Bang/2013 : Asst.Year 2012-2013 M/S.Google India Private Limited The Deputy Commissioner Of No.3, Rmz Infinity Tower-E Income-Tax (International V. 4Th Floor, Old Madras Road Taxation), Circle 1(1) Bangalore. Bangalore – 560 016. Pan : Aaccg0527D. (Appellant) (Respondent) Appellant By : Sri.Percy Pardiwala, Sr.Advocate, Sri.Anmol Anand, Advocate, Miss.Priya Tandon, Advocate & Sri.Vinay Mangla, Ca Respondent By : Sri.K.V.Aravind, Standing Counsel Date Of Pronouncement : 19.10.2022 Date Of Hearing : 13.09.2022 O R D E R Per George George K, Jm : These Appeals At The Instance Of The Assessee Were Originally Disposed By The Itat Vide Its Common Order Dated 23.10.2017. On Further Appeal At The Instance Of The Assessee, The Hon’Ble High Court Vide Judgment Dated 17.04.2021 In Ita No.883/2017, 897/2017 To 899/2017, Restored The Matter To The Itat For De Novo Consideration. The Relevant Finding Of The Hon’Ble High Court Reads As Follows:-

For Appellant: Sri.Percy Pardiwala, Sr.Advocate, Sri.Anmol AnandFor Respondent: Sri.K.V.Aravind, Standing Counsel
Section 201Section 201(3)Section 9(1)(vi)

IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES “C”, BANGALORE Before Shri George George K, JM & Ms.Padmavathy S, AM IT

M/S Google India Private Limited, Bangalore vs. Dy. D.I.T., Bangalore

In the result, the appeals filed by the assessee are allowed

ITA 1513/BANG/2013[2009-10]Status: DisposedITAT Bangalore19 Oct 2022AY 2009-10

Bench: Shri George George K, Jm & Ms.Padmavathy S, Am It(Tp)A No.1513/Bang/2013 : Asst.Year 2009-2010 It(Tp)A No.1514/Bang/2013 : Asst.Year 2010-2011 It(Tp)A No.1515/Bang/2013 : Asst.Year 2011-2012 It(Tp)A No.1516/Bang/2013 : Asst.Year 2012-2013 M/S.Google India Private Limited The Deputy Commissioner Of No.3, Rmz Infinity Tower-E Income-Tax (International V. 4Th Floor, Old Madras Road Taxation), Circle 1(1) Bangalore. Bangalore – 560 016. Pan : Aaccg0527D. (Appellant) (Respondent) Appellant By : Sri.Percy Pardiwala, Sr.Advocate, Sri.Anmol Anand, Advocate, Miss.Priya Tandon, Advocate & Sri.Vinay Mangla, Ca Respondent By : Sri.K.V.Aravind, Standing Counsel Date Of Pronouncement : 19.10.2022 Date Of Hearing : 13.09.2022 O R D E R Per George George K, Jm : These Appeals At The Instance Of The Assessee Were Originally Disposed By The Itat Vide Its Common Order Dated 23.10.2017. On Further Appeal At The Instance Of The Assessee, The Hon’Ble High Court Vide Judgment Dated 17.04.2021 In Ita No.883/2017, 897/2017 To 899/2017, Restored The Matter To The Itat For De Novo Consideration. The Relevant Finding Of The Hon’Ble High Court Reads As Follows:-

For Appellant: Sri.Percy Pardiwala, Sr.Advocate, Sri.Anmol AnandFor Respondent: Sri.K.V.Aravind, Standing Counsel
Section 201Section 201(3)Section 9(1)(vi)

IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCHES “C”, BANGALORE Before Shri George George K, JM & Ms.Padmavathy S, AM IT

Diamonds 'R' Us, Mumbai vs. Deputy Commissioner of Income Tax - Central Circle 6(4), Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 539/MUM/2018[2014-15]Status: DisposedITAT Mumbai12 Oct 2022AY 2014-15

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 36Section 36(1)(iii)

which inter alia includes trading. The extract of the rule 76 is reproduced as under (Emphasis supplied). "Trading, warehousing, research and development services, computer software services, including information enabled services such as back office operations, call centers, content development or animation, data processing, injuring and design, graphic information systems services

Diamonds 'R' Us, Mumbai vs. Deputy Commissioner of Income Tax - Central Circle 6(4), Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 538/MUM/2018[2013-14]Status: DisposedITAT Mumbai12 Oct 2022AY 2013-14

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 36Section 36(1)(iii)

which inter alia includes trading. The extract of the rule 76 is reproduced as under (Emphasis supplied). "Trading, warehousing, research and development services, computer software services, including information enabled services such as back office operations, call centers, content development or animation, data processing, injuring and design, graphic information systems services

Diamonds 'R' Us, Mumbai vs. Deputy Commissioner of Income Tax - Central Circle 6(4), Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 537/MUM/2018[2012-13]Status: DisposedITAT Mumbai12 Oct 2022AY 2012-13

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 36Section 36(1)(iii)

which inter alia includes trading. The extract of the rule 76 is reproduced as under (Emphasis supplied). "Trading, warehousing, research and development services, computer software services, including information enabled services such as back office operations, call centers, content development or animation, data processing, injuring and design, graphic information systems services

Diamonds 'R' Us, Mumbai vs. Assistant Commissioner of Income Tax - Central Circle 6(4), Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 536/MUM/2018[2011-12]Status: DisposedITAT Mumbai12 Oct 2022AY 2011-12

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 36Section 36(1)(iii)

which inter alia includes trading. The extract of the rule 76 is reproduced as under (Emphasis supplied). "Trading, warehousing, research and development services, computer software services, including information enabled services such as back office operations, call centers, content development or animation, data processing, injuring and design, graphic information systems services

DCIT - 8(2)(1), Mumbai vs. Siemens Technology and Services Pvt. Ltd., Mumbai

In the result, the appeals of the revenue are dismissed and appeal of the assessee is partly allowed

ITA 3247/MUM/2018[2005-06]Status: DisposedITAT Mumbai12 Oct 2022AY 2005-06

Bench: Shri Kuldip Singh & Shri Amarjit Singh

For Appellant: P.J. Pardiwala &For Respondent: Ashok Kumar Kardam
Section 10ASection 143(2)Section 143(3)

purpose and they have begun manufacture/production of 3032 & 3247, 2947/Mum/2018 8 DCIT-8(2)(1) Vs. M/s Siemens Technology and Services Pvt. Ltd. computer software in the software technology Park after first April 1994. In view of these facts, I'm of the opinion that the AO was not justified

DCIT - 8(2)(1), Mumbai vs. Siemens Technology & Services Pvt. Ltd., Mumbai

In the result, the appeals of the revenue are dismissed and appeal of the assessee is partly allowed

ITA 3032/MUM/2018[2006-07]Status: DisposedITAT Mumbai12 Oct 2022AY 2006-07

Bench: Shri Kuldip Singh & Shri Amarjit Singh

For Appellant: P.J. Pardiwala &For Respondent: Ashok Kumar Kardam
Section 10ASection 143(2)Section 143(3)

purpose and they have begun manufacture/production of 3032 & 3247, 2947/Mum/2018 8 DCIT-8(2)(1) Vs. M/s Siemens Technology and Services Pvt. Ltd. computer software in the software technology Park after first April 1994. In view of these facts, I'm of the opinion that the AO was not justified

Siemens Technology & Services Pvt. Ltd.(Erstwhile Known As Siemens Information Systems Ltd.), Mumbai vs. DCIT- Circle -8(2)(1), Mumbai

In the result, the appeals of the revenue are dismissed and appeal of the assessee is partly allowed

ITA 2947/MUM/2018[2006-07]Status: DisposedITAT Mumbai12 Oct 2022AY 2006-07

Bench: Shri Kuldip Singh & Shri Amarjit Singh

For Appellant: P.J. Pardiwala &For Respondent: Ashok Kumar Kardam
Section 10ASection 143(2)Section 143(3)

purpose and they have begun manufacture/production of 3032 & 3247, 2947/Mum/2018 8 DCIT-8(2)(1) Vs. M/s Siemens Technology and Services Pvt. Ltd. computer software in the software technology Park after first April 1994. In view of these facts, I'm of the opinion that the AO was not justified