2014 (1) TMI 311

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... Respondent. ORDER Heard both sides on the stay petition. 2.1 The appellants, M/s. Dell India Pvt. Ltd. are engaged in manufacture of computers and are using the licensed software of M/s. Microsoft Inc., USA. They download the software through internet and the invoices for the software so downloaded by the appellant are raised by Microsoft Inc. on their sister concern, M/s. Dell Products I....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....on of the show-cause notice and the findings of the Commissioner, submits that it is merely a case of procuring the required software from Microsoft Inc. directly by the appellant and making payments through their group concern based in USA and the group concern getting reimbursement from the appellant. The group concern based in USA has not been paid any service charge for this transaction. There....