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18. Facts of the case are that the assessee is engaged in the business of development and export of computer software. During the year under consideration, the assessee had incurred a sum of Rs. 585,30,20,535 towards purchase of software. As a result of the outlay, the assessee secured a license to use the software. The license was available for a limited period. The license was renewable, by payment of the fees at pre-defined intervals. The assessee secured limited right of use of the software. It did not secure the source code. It was prevented from modifying or duplicating the software. It could not decompile or disassemble the software. No derivative works could be created. The assessee was permitted to use the software for IT(TP)A No.735/Bang/2018 & M/s. Infosys Limited, Bangalore its business, in a limited manner. The impugned expenditure did not result in acquisition of any asset by the assessee.