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6. The assessee did not acquire the source code of the said software/s, and could only use the same as a user in its own export business, and contrary to the findings of the assessing officer, did not acquire any rights to reproduce or sell or distribute the same or otherwise modify or copy or amend the same in any manner. It is precluded from these activities by the nature of the single user/computer installation per user.
7. It therefore is submitted that the payments were for a copyrighted article and not in the ITA.No.406 to 411/Hyd/2012 M/s. Moldtek Technologies Ltd., Hyderabad.