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“software technology park”

DeductionsSection 10ASection 10A110 judgments

The decision most relied on for software technology park is ITO v. Sak Soft Ltd. (30 SOT 55), cited in 80 judgments on BharatTax.

Leading authorities on software technology park

ITO v. Sak Soft Ltd.
30 SOT 55 · 2009 · ITAT
80
citing judgments

When computing the deduction under Sections 10A or 10AA, if certain expenses (like those incurred in foreign currency or communication expenses) are excluded from 'export turnover' in the numerator, the same expenses must also be excluded from 'total turnover' in the denominator to ensure consistent calculation.

CIT v. WIPRO GE MEDICAL SYSTEM LTD.
358 ITR 518 · 2013 · High Court
19
citing judgments

To qualify for a Section 10A deduction, an undertaking must be independent of the assessee's existing undertakings, rather than merely an expansion of existing business.

PCIT v. Macquarie Global Services (P.) Ltd.
102 Taxmann.com 272 · 2019 · High Court
15
citing judgments

A deduction under Section 10AA cannot be withdrawn in a subsequent year if it was accepted in the first year of operations and the second year, by re-examining factors relevant to the initial year.

Shri Nagesh Chundur v. CIT
358 ITR 521 · 2013 · High Court
11
citing judgments

A new industrial undertaking qualifies for deduction under section 10A of the Income Tax Act even if it commenced production before seeking registration as a Software Technology Park (STP), provided it meets the requisite conditions.

Judgments citing software technology park

M/S. Zensar Technologies Ltd ( Formerly International Computers (India) Ltd ), Mumbai vs. The CIT -2

In the result, the appeal of the assessee is partly allowed

ITA 4137/MUM/2007[2002-2003]Status: HeardITAT Mumbai17 May 2022AY 2002-2003
Section 10ASection 115JSection 14ASection 263Section 28Section 80H

erred in allowing set off of losses and unit eligible for claiming deduction u/s.10A of the Act against non-Software Technology Park (STP) Unit. 7.1. We have heard rival submissions and perused the materials available on record. We find that assessee earned profits in its Ashok Plaza Unit at Pune

M/S. Infineon Technologies India Pvt Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bengaluru

In the result the appeal filed by assessee stands allowed partly

ITA 2870/BANG/2017[2013-14]Status: DisposedITAT Bangalore31 Mar 2022AY 2013-14

Bench: Shri B. R. Baskaran & Smt. Beena Pillaiit(Tp)A No.2870/Bang/2017 Assessment Year: 2013-14 M/S. Infineon Technologies India Pvt. Ltd. Deputy Commissioner 9Th Floor Prestige Of Income-Tax Thirulakshmi Vs. Circle-3(1)(1) No.11 M.G. Road Bengaluru Bengaluru 560 001 Pan No : Aabcs6967N Appellant Respondent Appellant By : Shri K.R. Vasudevan, A.R. Shri Sumer Singh Meena, Respondent By : D.R. Date Of Hearing : 13.01.2022 Date Of Pronouncement : 31.03.2022 O R D E R Per Beena Pillai: Present Appeal Is Filed By Assessee Against The Order Dated 16/10/2017 Passed By The Ld.Dcit Under Section 143(3) R.W. Section 144C(13) For Assessment Year 2013-14 On Following Grounds Of Appeal: “The Grounds Mentioned Hereinafter Are Without Prejudice To One Another.

For Appellant: Shri K.R. Vasudevan, A.R
Section 133(6)Section 143(3)Section 144C(13)Section 40Section 92C

Chip Card and Security, Industrial Multi- Market and Wireless & Wire line communication domains. TIPL, a 100% export oriented unit (EOU), registered with the Software Technology Park of India (STPI) provides marketing support services to its parent Company. ITIPL provides marketing support services to 'Infineon Singapore. 3. The details

M/S. Vantage Agora Marketing Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 12(5), Bangalore

In the result, the appeal filed by assessee stands allowed for statistical purposes

ITA 373/BANG/2020[2009-10]Status: DisposedITAT Bangalore07 Mar 2022AY 2009-10

Bench: Shri. B.R. Baskaran & Smt. Beena Pillaiassessment Year : 2009-10 M/S. Vantage Agora Marketing Pvt. Ltd., # Pixel Park-A, 4Th Floor, The Deputy Pes Institute Of Commissioner Of Technology, Income Tax, Vs. Hosur Road, Electronic Circle – 12(5), City, Bangalore. Bangalore – 560 100. Pan: Aaccv1443P Appellant Respondent : Shri V. Chandrashekar, Assessee By Advocate : Smt. Priyadarshini Revenue By Basaganni, Jcit (Dr) Date Of Hearing : 30-12-2021 Date Of Pronouncement : 07-03-2022 Order Per Beena Pillaipresent Appeal Has Been Filed By Assessee Against Order Dated 30/03/2016 Passed By The Ld.Cit(A), Mysore For Assessment Year 2009-10 On Following Grounds Of Appeal: “1. The Order Of The Hon'Ble Commissioner Of Income Tax (Appeals), Mysuru, Insofar As It Is Against The Appellant, Is Opposed To Law, Weight Of Evidence, Natural Justice, Probabilities, Facts & Circumstances Of The Appellant'S Case.

For Respondent: Shri V. Chandrashekar
Section 10ASection 234CSection 72

exempt under section 10A of the Act. The Ld.AO observed that assessee applied for registration of their unit under software technology Parks of India which was granted in the month of December 2008. The Ld.AO observed that, the assessee claimed exemption pertaining to 10A, for period of 3 months, towards

Tanglin Developments Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result, assessee’s appeals are allowed

ITA 146/BANG/2021[2017-18]Status: DisposedITAT Bangalore31 Jan 2022AY 2017-18

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri C Ramesh, C.AFor Respondent: Shri Jairam Raipura, CIT(DR OSD)
Section 43A

Assessing Officer. 4. We consider the facts in ITA No.143/Bang/2021 The assessee is in the activity of development of SEZ and software technology park known as Global Village, at Mysore Road, Bangalore. The exchange fluctuation loss claimed related to two foreign currency loans from HDFC Bank of Rs 400 crores ... respectively. The loans raised in foreign currency have been utilized for repayment of earlier loan for the purpose of development of SEZ and software technology park and also further development of such SEZ of which the assessee is in receipt of license fee which has been offered as revenue

Tanglin Developments Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result, assessee’s appeals are allowed

ITA 145/BANG/2021[2015-16]Status: DisposedITAT Bangalore31 Jan 2022AY 2015-16

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri C Ramesh, C.AFor Respondent: Shri Jairam Raipura, CIT(DR OSD)
Section 43A

Assessing Officer. 4. We consider the facts in ITA No.143/Bang/2021 The assessee is in the activity of development of SEZ and software technology park known as Global Village, at Mysore Road, Bangalore. The exchange fluctuation loss claimed related to two foreign currency loans from HDFC Bank of Rs 400 crores ... respectively. The loans raised in foreign currency have been utilized for repayment of earlier loan for the purpose of development of SEZ and software technology park and also further development of such SEZ of which the assessee is in receipt of license fee which has been offered as revenue

Tanglin Developments Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result, assessee’s appeals are allowed

ITA 144/BANG/2021[2014-15]Status: DisposedITAT Bangalore31 Jan 2022AY 2014-15

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri C Ramesh, C.AFor Respondent: Shri Jairam Raipura, CIT(DR OSD)
Section 43A

Assessing Officer. 4. We consider the facts in ITA No.143/Bang/2021 The assessee is in the activity of development of SEZ and software technology park known as Global Village, at Mysore Road, Bangalore. The exchange fluctuation loss claimed related to two foreign currency loans from HDFC Bank of Rs 400 crores ... respectively. The loans raised in foreign currency have been utilized for repayment of earlier loan for the purpose of development of SEZ and software technology park and also further development of such SEZ of which the assessee is in receipt of license fee which has been offered as revenue

Tanglin Developments Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Central Circle-1(3), Bangalore

In the result, assessee’s appeals are allowed

ITA 143/BANG/2021[2013-14]Status: DisposedITAT Bangalore31 Jan 2022AY 2013-14

Bench: Shri Chandra Poojari & Shri George George K.

For Appellant: Shri C Ramesh, C.AFor Respondent: Shri Jairam Raipura, CIT(DR OSD)
Section 43A

Assessing Officer. 4. We consider the facts in ITA No.143/Bang/2021 The assessee is in the activity of development of SEZ and software technology park known as Global Village, at Mysore Road, Bangalore. The exchange fluctuation loss claimed related to two foreign currency loans from HDFC Bank of Rs 400 crores ... respectively. The loans raised in foreign currency have been utilized for repayment of earlier loan for the purpose of development of SEZ and software technology park and also further development of such SEZ of which the assessee is in receipt of license fee which has been offered as revenue

Serco India Pvt. Ltd., Gurgaon vs. DCIT, Gurgaon

In the result, the appeal of the assessee is allowed

ITA 1460/DEL/2014[2009-10]Status: DisposedITAT Delhi10 Jan 2022AY 2009-10

Bench: Sh. Saktijit Deydr. B. R. R. Kumarita No. 1460/Del/2014 : Asstt. Year : 2009-10 Serco India Pvt. Ltd., Vs Dcit, 6Th Floor, Tower-B, Building No. 8, Circle-2, Dlf Cyber City, Phase-Ii, Gurgaon Gurgaon (Appellant) (Respondent) Pan No. Aajcs6704P Assessee By : Sh. Suraj Bhan Nain, Ca Revenue By : Sh. M. Baranwal, Sr. Dr Date Of Hearing: 04.01.2022 Date Of Pronouncement: 10.01.2022

For Appellant: Sh. Suraj Bhan Nain, CAFor Respondent: Sh. M. Baranwal, Sr. DR
Section 10ASection 143(3)Section 144C(13)Section 234BSection 271(1)(c)Section 92C

assessee company was involved in the business of development and export of computer software in an Undertaking registered under Software Technology Park of India and claimed deduction u/s 10A of the Act. The assessee has made total export turnover of Rs. 9,82,87,609/- in this undertaking and there

Deputy Commissioner of Income Tax Circle-7(1)(1), Bangalore vs. M/S Thought Works Technologies India Private Limited, Bangalore

In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue is dismissed

ITA 590/BANG/2019[2012-13]Status: HeardITAT Bangalore04 Jan 2022AY 2012-13

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.V.Sridhar, CAFor Respondent: Sri.Jairam Raipura, CIT-DR
Section 143(3)Section 43A

providing custom e-business application and platforms. The assessee is registered as a 100% Export Oriented Unit (EOU) and also registered under the Software Technology Park of India (STPI). For the M/s.ThoughtWorks Technologies (India) Pvt.Ltd.. assessment year 2012-2013, the return of income was filed on 27.11.2012 disclosing

Thoughtworks Technologies (India) Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle -7(1)(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed and the appeal filed by the Revenue is dismissed

ITA 580/BANG/2019[2012-13]Status: HeardITAT Bangalore04 Jan 2022AY 2012-13

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.V.Sridhar, CAFor Respondent: Sri.Jairam Raipura, CIT-DR
Section 143(3)Section 43A

providing custom e-business application and platforms. The assessee is registered as a 100% Export Oriented Unit (EOU) and also registered under the Software Technology Park of India (STPI). For the M/s.ThoughtWorks Technologies (India) Pvt.Ltd.. assessment year 2012-2013, the return of income was filed on 27.11.2012 disclosing

DCIT, Circle-12(1), New Delhi vs. Infrasoft Technologies Ltd., Mumbai

Accordingly, appeal filed by the learned assessing officer is dismissed

ITA 1761/DEL/2019[2007-08]Status: DisposedITAT Delhi25 Nov 2021AY 2007-08

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) Dcit, Vs. Infrasoft Technologies Ltd, Circle-12(1), Unit No. 86 & 87, Sdf Iii, New Delhi Seepz Midc, Andheri East, Mumbai Pan: Aaacb2817R (Appellant) (Respondent)

For Appellant: Shri Vijay Mehta, CAFor Respondent: Shri Ramesh Kumar, Sr. DR
Section 10Section 10ASection 143Section 80H

assessee that the documents mentioned in the table establishes the fact that a new establishment has been set up and registered with “Software Technology Park of India” (hereinafter STPI). 5.3 In the submission filed on 20.12.2017 the assessee has given a brief overview of the company from its inception regarding ... company continues to drive income from the business of development and sale of software products. The assessee company has been registered with the Software Technology Park of India (STPI). Assessee has submitted the STPI initial registration certificate dated 28.03.2000, STPI extension letter dated 19.03.2005 for further extension of next years

ACIT, Circle-7(1), New Delhi vs. Dlf Commercial Developers Ltd., New Delhi

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

ITA 9227/DEL/2019[2008-09]Status: DisposedITAT Delhi17 Nov 2021AY 2008-09

Bench: Shri Amit Shukla & Shri Prashant Maharishi

For Appellant: Shri R.S. Singhvi, CAFor Respondent: Shri J.K. Mishra, CIT-D.R
Section 143Section 143(3)Section 263Section 80Section 80I

different companies as its business, the lease rent received by the assessee from letting out buildings along with other amenities in a software technology park would be chargeable to tax under the head "Income from Business" and not under the head "Income from House Property". The judgment has been accepted

Qualcomm India Pvt. Ltd., New Delhi vs. Addl.CIT, Special Range-7, New Delhi

In the result, the appeal of the assessee is allowed

ITA 6421/DEL/2019[2015-16]Status: DisposedITAT Delhi01 Nov 2021AY 2015-16

Bench: Ms. Suchitra Kambledr. B. R. R. Kumar(Through Video Conferencing) Ita No. 6421/Del/2019 : Asstt. Year : 2015-16 Qualcomm India Pvt. Ltd., Vs Addl. Cit, Unit No. 201, 2Nd Floor, Tolstoy House, Special Range-7, 15, Tolstoy Marg, New Delhi-110001 New Delhi-110002 (Appellant) (Respondent) Pan No. Aaacq0231C

For Appellant: Ms. Ananya Kapoor, AdvFor Respondent: Ms. Anshu Shukla Pandey, CIT DR
Section 143(3)Section 92CSection 92C(3)(c)

Export Oriented Unit (EOU) for the development of the software at Development Centers in Hyderabad, Bangalore and Chennai which are registered under the Software Technology Parks of India (STPI) scheme. The Development Centers are engaged in rendering software development services and IT support services to its Associated Enterprises (AEs). Further

Cpa Global Support Services (I) Pvt. Ltd., New Delhi vs. ITO, New Delhi

In the result, the appeal of the assessee in ITA No

ITA 6815/DEL/2015[2011-12]Status: DisposedITAT Delhi01 Oct 2021AY 2011-12

Bench: Shri N.K. Billaiya & Shri Laliet Kumar

For Appellant: Shri G.C. Srivastava, AdvFor Respondent: Shri Surenderpal, CIT-DR
Section 143(3)Section 274Section 92Section 92C

facts of the case are that the assessee is a wholly owned subsidiary of CPA LLC. The assessee is registered with the Software Technology Park of India [STPI] and is an IT enabled support service provider rendering information technology enabled services related to IP Administration/renewal and data management services, proof

ACIT, New Delhi vs. M/S Noida Software Technology Park Ltd., New Delhi

In the result, appeal of the Revenue is dismissed

ITA 3178/DEL/2017[2012-13]Status: DisposedITAT Delhi08 Sept 2021AY 2012-13

Bench: The Ld. Cit(A) & The Ld. Cit(A) By Way Of Impugned Order Deleted Both The Additions. Revenue Is, Therefore, Before Us In This Appeal.

Section 14ASection 195Section 40Section 9

DELHI SHRI K.NARASIMHA CHARY, JUDICIAL MEMBER AND SHRI B.R.R. KUMAR, ACCOUNTANT MEMBER Assessment Year: 2012-13 ACIT, Circle 18(2), vs Noida Software Technology Park Ltd., New Delhi Scindia Villa, Sarojini Nagar, Ring Road, New Delhi AABCN0137F Assessee by None Revenue by Shri Gaurav Pundir, Sr. DR Date of Hearing ... dated 15/02/2017 passed by the learned Commissioner of Income Tax (Appeals)-38, New Delhi (“Ld. CIT(A)”), in the case of M/s Noida Software Technology Park Ltd (“the assessee”), for the assessment year 2012-13, Revenue preferred this appeal. 2. Assessee is a company engaged in the business of teleport

DCIT Circle-2, Gurgaon vs. Lalit Wadhwa, Gurgaon

In the result, the appeal filed by the Revenue is dismissed

ITA 4755/DEL/2014[2009-10]Status: DisposedITAT Delhi26 Aug 2021AY 2009-10

Bench: Shri O.P. Kant & Shri Amarjeet Singh[Through Video Conferencing] Assessment Year: 2009-10

Section 10BSection 143(3)

stated facts of the case are that the assessee, an individual, was carrying business of export of Information Technology (IT) enabled services from Software Technology Park (Noida) through proprietary concern, namely, M/s. Dotsplash. During the year under consideration, the assessee filed return of income on 26/09/2009, declaring total income

Avalon Business Associates, New Delhi vs. ITO Ward-41(5), New Delhi

In the result, appeal of the assessee is allowed for statistical purpose

ITA 1859/DEL/2019[2011-12]Status: DisposedITAT Delhi04 Jun 2021AY 2011-12

Bench: Shri G.S. Pannu, Hon’Ble & Shri K.Narasimha Charyassessment Year: 2011-12

Section 10Section 10ASection 10BSection 143(3)Section 263Section 80

purpose of this appeal, are that the assessee is a partnership firm, having registered as a 100% Export- Oriented Undertaking (EOU) with the Software Technology Park (Noida) for the Development/Manufacture and Export of Computer Software/IT enabled services vide Letter of Permission No. STPIN/APP/1152020/201299/70562 dated 15.01.2010 ("LOP"); that subsequently, in terms ... light of the submissions made on either side. Though Ld. AR argued at length stating that in view of the scheme under the software technology Park (STP) scheme, 1991 (STP scheme) and the electronic hardware technology Park scheme, 1993 (EHTP scheme) certain exceptions are carved out for R&D, software

DCIT, Circle- 11(1), New Delhi vs. Honeywell International (India) Pvt. Ltd., New Delhi

In the result, appeal of the assessee for assessment year 2011 – 12 is partly allowed

ITA 5801/DEL/2017[2011-12]Status: DisposedITAT Delhi24 May 2021AY 2011-12

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) M/S. Honeywell International Vs. Addl Cit (India) Pvt. Ltd, 1St Floor, Range-4, Unitech Trade Centre, New Delhi Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) Addl Cit, Vs. M/S. Honeywell Special Range-4, International (India) Pvt. Ltd, New Delhi 1St Floor, Unitech Trade Centre, Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) Dcit, Vs. M/S. Honeywell Circle-11(1), International (India) Pvt. Ltd, New Delhi 1St Floor, Unitech Trade Centre, Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) M/S. Honeywell International Vs. Dcit, (India) Pvt. Ltd, 1St Floor, Unitech Circle-11(1), Trade Centre, Sector-43, Block New Delhi C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent)

For Appellant: Shri Deeraj Kr. Jain, Sr. DRFor Respondent: Shri Rajan Vora, CA
Section 10ASection 234CSection 250Section 271(1)(c)

Coming to the appeal of the assessee the fact shows that in assessment year 2005 – 06, the assessee had set up a software Technology Park under the name and style of Global Customer Support Centre or call Centre Division which is engaged in providing information technology enabled services

Honeywell International (India) Pvt. Ltd., New Delhi vs. DCIT, Circle- 11(1), New Delhi

In the result, appeal of the assessee for assessment year 2011 – 12 is partly allowed

ITA 5770/DEL/2017[2011-12]Status: DisposedITAT Delhi24 May 2021AY 2011-12

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) M/S. Honeywell International Vs. Addl Cit (India) Pvt. Ltd, 1St Floor, Range-4, Unitech Trade Centre, New Delhi Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) Addl Cit, Vs. M/S. Honeywell Special Range-4, International (India) Pvt. Ltd, New Delhi 1St Floor, Unitech Trade Centre, Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) Dcit, Vs. M/S. Honeywell Circle-11(1), International (India) Pvt. Ltd, New Delhi 1St Floor, Unitech Trade Centre, Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) M/S. Honeywell International Vs. Dcit, (India) Pvt. Ltd, 1St Floor, Unitech Circle-11(1), Trade Centre, Sector-43, Block New Delhi C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent)

For Appellant: Shri Deeraj Kr. Jain, Sr. DRFor Respondent: Shri Rajan Vora, CA
Section 10ASection 234CSection 250Section 271(1)(c)

Coming to the appeal of the assessee the fact shows that in assessment year 2005 – 06, the assessee had set up a software Technology Park under the name and style of Global Customer Support Centre or call Centre Division which is engaged in providing information technology enabled services

M/S. Honeywell International (India) Pvt. Ltd., New Delhi vs. Addl. CIT (Inv.), New Delhi

In the result, appeal of the assessee for assessment year 2011 – 12 is partly allowed

ITA 6558/DEL/2016[2010-11]Status: DisposedITAT Delhi24 May 2021AY 2010-11

Bench: Shri Amit Shukla & Shri Prashant Maharishi(Through Video Conferencing) M/S. Honeywell International Vs. Addl Cit (India) Pvt. Ltd, 1St Floor, Range-4, Unitech Trade Centre, New Delhi Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) Addl Cit, Vs. M/S. Honeywell Special Range-4, International (India) Pvt. Ltd, New Delhi 1St Floor, Unitech Trade Centre, Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) Dcit, Vs. M/S. Honeywell Circle-11(1), International (India) Pvt. Ltd, New Delhi 1St Floor, Unitech Trade Centre, Sector-43, Block C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent) M/S. Honeywell International Vs. Dcit, (India) Pvt. Ltd, 1St Floor, Unitech Circle-11(1), Trade Centre, Sector-43, Block New Delhi C, Sushant Lok Phase-I, Gurgaon Pan: Aanca7954K (Appellant) (Respondent)

For Appellant: Shri Deeraj Kr. Jain, Sr. DRFor Respondent: Shri Rajan Vora, CA
Section 10ASection 234CSection 250Section 271(1)(c)

Coming to the appeal of the assessee the fact shows that in assessment year 2005 – 06, the assessee had set up a software Technology Park under the name and style of Global Customer Support Centre or call Centre Division which is engaged in providing information technology enabled services