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
license fees paid for the software with
the computer and the software were not purchased with their source codes
and such software were eligible
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
portions of
QTS's intellectual property portfolio, which
includes certain software rights essential to
and/or useful in the manufacture and sale of
certain ... alter,
modify, copy, translate or adopt the Source code
of AMSS and QRDA software. The assessee agrees
that this amount is taxable @ 10% under
notice that the assessee
licenses the software to the end user and they do not provide the source
code to them, as such ... issue holding that inasmuch as the assessee does not provide the
source code to the end-users and also in view of the decision
unregistered, design right
applications, trade secrets, know-how, information, data,
source codes and object codes, technology, specifications of
materials, formulae and processes, production methods,
discoveries ... shall not use or
disclose such source code and it shall immediately deliver nil
copies of such source code to Adobe, Nothing contained in this
details. This company is into medical
transcription, medical billing, medical coding, claims
processing and software development implementation services.
Ld. TPO held that since the comparables ... revenue's from operations are from different sources i.e.
medical transcription, billing and coding and EMR and SAAS.
However, the annual report states
Samsung India Electronics Pvt. Ltd., ... vs Acit, New Delhi on 4 October, 2019
IN THE
