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4. OWNERSHIP VERITAS retains all right, title and interest in the Licensed Software and Documentation and in all copies, improvements, enhancements, modifications and derivative works of the Licensed Software or Documentation including, without limitation, all patent, copyright, trade secret and trademark rights."

14. Perusal of this agreement suggests that neither there was any transfer of copyright nor the vendor has given any permission for commercial exploitation of the copyright of the software. No source codes etc have been supplied by the vendor to the assessee. There is no permission given to the assessee to make any modification or re-engineering of the software, which was supplied for the limited purpose of internal use of the assessee. Ownership with regard to title and interest in the licensed software is retained by the supplier. It is noted that Ld. CIT(A) has also gone through various agreements and thereafter recorded following observations at page 9 of his order:-