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INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
SHRI MANJUNATHA G, ACJ, SHRI K. NARASIMHA CHARY, J
IVY SOFTWARE DEVELOPMENT SERVICES PRIVATE LIMITED HYDERABAD – Appellant
Versus
ASST. COMMISSIONER OF INCOME TAX CIRCLE-2(1) HYDERABAD – Respondent
| Table of Content |
|---|
| 1. counsel for the assessee submitted (Para 4 , 5 , 6 , 7) |
| 2. we have heard both sides (Para 8 , 9 , 10 , 11 , 12 , 13 , 14 , 15 , 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24 , 25 , 26 , 27 , 28 , 29 , 30 , 31 , 32 , 33 , 34 , 35 , 36) |
| 3. in the result, appeal of the assessee (Para 37) |
ORDER PER MANJUNATHA G, A.M. :
This appeal has been filed by the assessee against the final assessment order dated 16.10.2019 passed by the Assessing Officer u/sec.143(3) r.w.s.144C(13) in pursuance to the directions of the Disputes Resolution Panel-1, Bengaluru, dated 06.09.2019, passed u/sec.144C(5) of the Income Tax Act, 1961 [in short “the Act”].
2. Brief facts of the case are that, the appellant company is engaged in the business of providing Software Development and Management Services to it’s Associated Enterprises [in short “AE”] which are in the nature of development of modern gaming software and software maintaining services. The appellant undertakes software coding according to functional specifications and software requirement analysis agreed with AE. It receives technical assistance from it’s AE if required during coding coupled with regular reviews and feedback by the AE. It
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