right to modify the source code; ii) the source code behind any of the
applications / software is accessed only by Symbiotics ... from the analysis undertaken by Symbiotics Ltd. UK
using Adapt software. The source code of the software is accessed only by
Symbiotics
India, Vs ACIT,
1st Floor, Plate B, Office Block-1, East CPC , TDS,
Didwai Nagar, New Delhi-110023 Ghaziabad, U.P.-201010
(APPELLANT) (RESPONDENT ... late deposition of
TDS.
4. In this regard, the assessee filed a letter to TDS- CPC on
30.11.2017 clarifying that total TDS for July
Qualcomm Incorporated, Usa vs Dcit, Circle- 3(1)(1), Intl. Taxation, ... on 13 June, 2023
assessee. The source code of the
license which could provide information of the working of the
applications/ software would never be shared with the customers
software; (ii) rent, lease, timeshare or otherwise
grant access to the software or its results or
sublicense, distribute or otherwise transfer the
software ... software, or any part thereof, or merge the
software with other software; (iv) reverse
engineer, decompile, disassemble or otherwise
attempt to derive the source code
Software
by persons other than Buyer's employees, consultants or
implementors of the Software;
(d) write or develop derivative work (meaning any new code ... right to decompile the software even though
it is limited.
3. The vendor has agreed to part with the source code 9though
in a protected
treated software license and maintenance charges
received by the appellant of Rs. 12,32,61,326/- for
giving right to use of computer software ... does it provide the member firms the
source code or object code pertaining to the software
applications and it merely grants right
While processing the return, Centralized Processing Centre [ CPC ]
did not allow credit of Tax Deducted at Source [TDS]. The assessee
follows the Accrual System ... income from
sale of software when invoices are raised. During the year under
consideration, the assessee had sold software to its two customers in
India
terms of which the assessee has granted licence to use certain
standardized software to the customer. The licences provided to
the end users ... users of the licnese do not have any access to the source code,
nor there was any transfer of right in process
that technology has been made available for rendering
technical services. The source code of the IT applications
hosted on central technology platform has not been ... recipient of the services. While providing services
for centralized provision of hardware, software, and
desktop support services, Software programming and
development, Data communication support
