assessee;
The Distributors do not have a right to the source code of such software
products;
The Distributors are not permitted to modify, translate ... documentation;
The Distributors are not permitted to create the source code of the
software products supplied under the Agreements;
The Distributors are not expressly permitted
does not
have any access to the source code. What is available for their use
is software product as such and not the process embedded ... software continues to be owned by the assessee and what
WIPRO/IBM is getting mere access to the software. The source code
embedded
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
Acit Cir 11(3)(1), Mumbai vs Total Oil India P. Ltd, Mumbai on 10
Total Oil India P. Ltd, Mumbai vs Acit Cir 11(3)(1), Mumbai on 10
M Model Global Services Pvt. Ltd., Navi ... vs Acit 15(2)(2), Mumbai on 15
Reliance Industries Limited, Mumbai vs Assistant Commissioner Of Income Tax- ... on 10 November, 2020
THE
M/S. Nicholas Piramal India Ltd., ... vs Acit Cir. - 7(1), Mumbai on 20 February
Inmarsat Global Limited, Mumbai vs Dcit (It) Circle 2(2)(1), Mumbai on 23 October
Dcit Cir 7(3)(2), Mumbai vs Piramal Enterprises Ltd, Mumbai on 15 January, 2020