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TMI Blog2011 (9) TMI 787X X X X Extracts X X X X X X X X Extracts X X X X ..... veloped by them as advised by their clients and therefore, their activities should be treated as falling under the “Information Technology Software Services” under Section 65(105)(zzzze) - Held that: the agreements are not for mere supply of manpower but for undertaking entire activities relating to development of software to the satisfaction of their clients including modification and upgradation ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . The applicants are undertaking certain services to parties, like M/s. Motorola India Electronics Ltd., M/s. ABB Global Services, M/s. Philips Software, M/s. Infineon Technologies India Pvt. Ltd., M/s. Staccato Communications Inc. USA who are also STP units. According to the applicants, they are involved in development of software, testing of the same and undertaking modification and upgradation ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1,640 stands demanded as Service tax along with interest besides imposition of penalty. 4. The learned Advocate for the applicants, after taking us through the agreements entered between the applicants and their clients, submits that they undertake to fulfledged development of software for various applications as desired by their clients. For the said purpose, they deployed their manpower both a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ty. He submits that it is merely a case of supply of qualified manpower for the various clients for developing software by the latter. 6. We have carefully considered the rival submissions and examined the agreements. On perusal of the agreements, we, prima facie, counter with the submissions made by the learned Advocate that the agreements are not for mere supply of manpower but for undertaking ..... X X X X Extracts X X X X X X X X Extracts X X X X
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