Bench: Shri V. Durga Rao & Shri D.S. Sunder Singhappellant Respondent
VA, USA (VLS) but never recruited any manpower to the said organization or any other person either in USA or in India. The assessee also furnished various details of various software developed by it and supplied to VLS. 3.5. Regarding higher margin, the assessee submitted that the companies listed by the AO in the assessment order are into software services