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(v) The collaboration arrangements shall cover the supply of source codes or system and application software.
(vi) The PMP shall be settled to the satisfaction of the government.........

Yours faithfully, Sd/ (S.H. Keswani) Under Secretary to the Government of India"

33. The authorised representative of the assessed, on the other hand, has apart from relying upon the impugned order and various decisions cited by him has also tried to make a case that this was a composite agreement and the use of the words granted and conveyed in article 6.1 clearly imply that the subject-matter of dispute was clearly a case of outright sale/transfer of technology and where the parties intended it to be otherwise, there as in clause 6(i)(ii) the amount is clearly defined as royalty and necessary taxes have been paid thereupon on the licensed products manufactured by HCL India. Our attention has also been invited to the title of this agreement which clearly uses the word technology transfer. Reference has also been made to article 2 of this agreement which reads as under :