Maximojo Software Pvt. Ltd.,, Pune vs Deputy Commissioner Of Income-Tax,, on 21 March, 2017
आयकर अपील य अ धकरण पण
ु े यायपीठ ... Respondent Year
Maximojo Software Pvt. DCIT( CPC )- 2013-14 Qr-1 24Q
1-11 2432/PUN/2016 Ltd., TDS
right to use computer software and owns all right, title and interest
in the software, therefore, what the supplier parts with to the end-user ... source code or object code of computer had been
7
ITA No.1433/PUN/2014
Tata Technologies Ltd.
protected and not available freely, these softwares
details. This company is into medical
transcription, medical billing, medical coding, claims
processing and software development implementation services.
Ld. TPO held that since the comparables ... revenue's from operations are from different sources i.e.
medical transcription, billing and coding and EMR and SAAS.
However, the annual report states
restriction
on the use to which transferee can put the software."
34. Further, the Authority For Advance Ruling in the case of GeoQueste
SystemsB ... placed on the user of software
and the fact that the license/customerhad no right to interfere with
source code and that the licensed produce
clinical
trial study based on the clients requirement: and
(b) providing Software Development Services to Cenduit LLC on a
contract basis ... source code of the IRT to Cenduit India and accordingly the configuration
does not result in development / creation of a new software / technology.
In configuring
IXOS
Software Asia Pte. Ltd., No. 6 Temasel Boulevard, #2-06,
Suntech Tower Four, Singapore 038986 for supply of a
software called "IXOX eCON ... enable operation of the program
within our own business only. No source code or
programming language or technique will be provided to us
with
Application remains with assessee and end users have not been given
source code of the application which constitute technical knowledge ... find force in the contention of Ld. Counsel, that
when no source code was shared with the end users, said end user cannot
be said
only use the software, only in object
IT(IT)A No.1099/Bang/2023
Informatica LLC, Bangalore
Page 5 of 9
code format. Clause ... thereof or adapt, translate, reverse engineer,
decompile or otherwise derive the source code for the products or
allow third parties to do so. Clause
such software. These exemptions were notified to
ensure that while importing or manufacturing packaged
software, the importer/manufacturer is spared from paying
customs duty/excise ... representation of instructions, data, sound or image,
including source code and object code, recorded in a
machine readable form, and capable of being manipulated
Linde Engineering India Private ... vs Vadodara-I on 6 November, 2023
CUSTOMS, EXCISE & SERVICE
