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2015 (2) TMI 20 - HC - Income TaxBenefit of Section 10B - whether assessee is engaged in activity which can be termed “manufacture”? - Held that:- In the present case Section 10B uses the expression “manufactures or produces… things or computer software”. The four stage process of compiling material, collating the text, designing the layout, scanning, digital image editing (to remove distortion) and final arrangement of the data, ultimately transmitted according to the customer’s specification - and ready to be used for printing, (or even e-Book publication) is undoubtedly manufacture or production. - Decided in favour of the assessee. Whether assessee’s manufacturing activity described earlier results in “computer software” - Held that:- In the present case, the work which ultimately results as the culmination of the assessee’s efforts of compiling, editing, digital designing, etc. “is transmitted or exported from India to any place outside India by any means". It is, therefore, computer software that are produced or manufactured, to qualify for benefit under Section 10B.- Decided in favour of the assessee
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