assessee had argued that:
a) Software is sold in the same manner as telecom equipment,
b) The software is an integral part of the telecom ... customers.
e) No access to the "source codes" in the software is granted to the
customer.
f) Payment for software is not related
agreement to provide all necessary technical
information/know-how (hardware and software of GSM BSS) as to enable
the petitioner to manufacture ... furnished to BSNL; furthermore, the
technology was transferred from "source code" level from VTiDirect to
TECL. It was submitted that each of these
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