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(i) Diagnostic of problems or issues with the product
(ii) Reasonable efforts to resolve reported and verifiable errors in the product so that it performs materially as described in the IT(IT)A No.260/Bang/2025 Q2 Software Inc., Bengaluru product documentation.
(iii) A review of cases logged by CDSU; and if needed, a recommend specific organization and process changes to help the customer comply with the support policies 4.3 The assessee company has also provided services to Cloudkaptan Consultancy Services Private Limited ("Cloudkaptan") under a Statements of Work ("SOWs"). These services were primarily to be provided to Cloudkaptan's clients outside India to install, configure, customize and otherwise integrate Q2 software as a service product into such customers environment wherein the customers had already purchased licensed software from Q2 under a separate agreement. These consultancy services provided by Q2 to Cloudkaptan during the subject AY 2022-23 was to assist the Cloudkaptan's customers outside India.

sub contractors / clients. Even in the context of customized software provided by the Assessee company to it is customers, the SC in Engineering Analysis (At para 117) held as follows:

IT(IT)A No.260/Bang/2025 Q2 Software Inc., Bengaluru "117. The conclusions that can be derived on a reading of the aforesaid judgments are as follows:

Therefore, what is important is the nature of rights in the licensing Agreement for the customized software. If it is a mere use -

only right to use even if it is a customized software will not amount to royalty. The decision of the Bangalore ITAT relied on by the AO in the case of Filtrex Technologies (P.) Ltd.[2011] 47 SOT 69 (Bangalore Trib.) is distinguishable on facts, given that said case involved a clear knowledge transfer of the manufacture of carbon blocks used in water purification system. 

platform etc. As per
the AO, the same
would    amount     to
"make available" of
knowledge etc.

Para 17 (ii) of FAO      The AO has failed to appreciate that

(of both AY 2021-22 presence of a customizable software to suit & 2022-23) the needs of a client does not imply that the technical knowledge etc. used in the The AO has held that development of the software itself is made the AE/ client are available to the AE/ customer. Technical enjoying enduring know-how of the software would not be benefit from the shared with the customer and the software knowledge. He has itself is akin to goods/copyrighted article held that the entire as held by the SC. It is submitted that the software is support services which are ancillary to the customizable to suit sale of software is not FTS/FIS. Appellant the needs of the client relies on the following judicial precedence: