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"Explanation-4 inserted by the Finance Act, 2012 has puts at rest all the controversies and doubts. It expressly states that transfer of all or any rights in respect of any right, property or information includes and has always included transfer of all or any right for use or right to use a computer software including granting of a licence irrespective of the medium through which such right is transferred. Therefore, the terms of Cost Sharing Agreement explicitly mention that the Canadian Company has developed internal telecommunication and communication tool which is accessible only to :-9-: ITA. Nos: 1573, 1574 & 1575/Chny/2023 SA Nos: 20 & 21/Chny/2024 the members of CGI worldwide. Therefore it is an intranet facility. Further it declares that the Canadian Company holds the intellectual property rights in the said CGI Information Technology Infrastructure facility. It has allowed the assessee to use the said facility subject to the terms and conditions stipulated in the said agreement."