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
including at PoC level, the contract shall be
terminated.
3. Source code of software of camera should be taken
from the supplier/OEM.
4. Before
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
have
also made observations in their respective orders about the source
code of the software and have further stretched the softwares to
equate it with ... 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
customize the software for the assessee, and also the source
code of the software. For all these details, the Learned Senior Advocate
Page | 15
expressed ... advertisement services were the service provider and the source code of
the software is now not available as it was used only for one-year
payable salary adjusting the wrong total
made by him in the NIC software. After that he used to get it transferred
into his bank accounts ... State Vs Vikas Rana 12
alongwith the CD containing source code of software were sent to CFSL
Hyderabad for analysis on 07.10.2009 and the report
find that the aforesaid
comparable, viz. Accentia Technologies Ltd. was engaged in software
development services and was thus functionally different from the assessee
company ... latter was generating income from three sources, i.e.
Medical Transcription, Billing & Coding and Software development &
implementation, but however no segmental information
