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with information, documentation, software, source code and other proprietary intellectual property to be used in performing service under the agreements. It is also agreed between the parties that all intellectual property rights including patents, software, trade secrets, related documentation etc. lead by assessee in performing services under the agreement shall fully vested with the AE's. Thus assessee jointly develops software by the virtual terms across the globe and communicate regularly with other development teams through video and audio conferencing facilities. This helps in synchronising the code being developed. It has been submitted in the TP study that assessee undertakes training of employees, limited quality controls, limited testing of software. It does not involve integration and implementation of post- same services.