source code can
always generate the executable machine code at will. Not
much value is added by transfer of binary executable
once the source code ... source code. It was contended
by Ld. Counsel that there was no absolute transfer of source
code of the assessee to Reliance. In fact, source
addressed to M/s. Lee & Nee Software (Export) Ltd. As
regards to the source code, it was stated that the documents
were lying with ... Shreepati Com pute rs) Page 29
5. The source code of the softwares developed could
not be provided by the appellant firm as well
make copies. It was further submitted that in this
case source-code was also given to the assessee which was a unique ... because the end users by using the
software do not have any access to the source codes. What is
available for their use is software
other form' would seem to indicate that the source code and object
code of a computer programme are entitled to copyright protection ... which the ideas are expressed in the source code are protected.
26. In the past, software were often sold as an integral part
this case, no source code was
supplied by the assessee. The customer had no right to use or
re-use the software elsewhere, the software ... reconstruct or discover the source
code, etc. This clause clearly lays down that customer shall not
reproduce the software or any of the documentation provided
this
case, no source code was supplied by the assessee. The customer had
no right to use or re-use the software elsewhere, the software ... reconstruct or discover the source code, etc. This clause
clearly lays down that customer shall not reproduce the software or
any of the documentation provided
merits, Tribunal held at para 71 of the order that
the Software that was purchased from WSL was installed on
the serve ... they held that the names of WSL appears in the source code
of the software. Also at para 75, Tribunal held that the
employee
wherein it was held that the sale of software was
hit by the Sale of Goods Act . The assessing officer held
that ... agreement there was no provision in the
agreement for referring the source code to the U.S.
Company. The agreement was for perpetuity
that the company is into diversified
activities like development of software, legal process out sourcing,
health care management, etc. A reference to the Profit ... solutions in health care. It is mainly medical transcription company
doing medical coding, medical billing and receivables management
services. The BPO services has not been
Religare Technova Global Solutions ... vs Acit Cir 2(1), Mumbai on 9 December, 2016
IN
