changes in the source
code and source code could be kept confidential, which gives rise to another
meaning to a licensed software that ... under the DTAA, he reiterated that as source code or the object code of
software had been protected under the Copyright Act , the software could
under:
"1. Exensys Software Solutions Ltd falls under the following
nature of software services:
· Software Product Company -- who develops software
products by following ... wherein right to use the
software is transferred without giving a source code.
· Software Development Service Provider - who does a portion
of the described software
assessee
under this segment.
Provision of software development and chip design service
segment
While providing software support development service to the AE,
assessee has entered ... 2014
AY: 2009-10
Qualcomm India P Ltd.
with information, documentation, software, source code and other
proprietary intellectual property to be used in performing service
Infrasoft is the provision of "Source
Code" & "Object Code" of the supplied software to the client.
After becoming a party ... software, software core
derivatives and software derivatives. Moreover, the agreement
provides that the assessee 'shall refrain from providing such
software and software core derivatives
company which
develops a software product by following all the above steps involved
in creating a software is a software development company and in
this ... right to
use the software is transferred without giving the source code. Unlike
these software development companies, pure software development
service provider does a portion
that the assessee did not have any
right to the source code of software products and was not permitted to
modify the software products, including ... source code in the software. The ASL software products were developed
and marketed by it were in the nature of shrink-wrap-software-products
that
company;
the distributors did not have a right to the source code of such software products;
the distributors were not permitted to modify, translate ... documentation;
the distributors were not permitted to create the source code of the software products
supplied under the agreements;
the distributors were not expressly permitted
embedded in the software, it cannot be held that either WIPRO/IBM are
using the process that has gone into the software or that they ... software continues to be owned by the assessee and what WJPRO/IBM
is getting mere access to the software. The source code embedded
maintained the time records or material like source code
of the software developed to indicate that the firm was actually involved in
developing software. During ... examined are
(a) The act of development of software as shown in source codes
and in email correspondence indicating the consultation and
changes made
license fees paid for the software with
the computer and the software were not purchased with their source codes
and such software were eligible