using
licensor's source code. As per the said clause, the source code and underlying
algorithm of the software are the assessee ... using licensor's
source code. As per the said clause, the source code and underlying algorithm
of the software are the assessee
right to modify the source code; ii) the source code behind any of the
applications / software is accessed only by Symbiotics ... from the analysis undertaken by Symbiotics Ltd. UK
using Adapt software. The source code of the software is accessed only by
Symbiotics
Qualcomm Incorporated, Usa vs Dcit, Circle- 3(1)(1), Intl. Taxation, ... on 13 June, 2023
software in object code format; (b) to modify and enhance (i)
the object code version of the software to the extent, if any,
provided ... documentation that the GTIL
provides with the software; and (ii) the source code version of the
software to the extent necessary to correct errors, ingredients
parting with the
copyrights on the software. It is further submitted that there is no access to
source code being given up by Finastra Singapore ... user does not
have any right on the source code of the software product. The end user
does not own any right on the copyrights
assessee. The source code of the
license which could provide information of the working of the
applications/ software would never be shared with the customers
Software is licenced, not
Products or the metadata sold.
created by the Products or
otherwise obtain or derive the 3. LIMITATIONS ON END
source code ... Products or discover the source code or
the metadata created by the algorithms of, the Software
Products for outsourcing, or (except and only
software; (ii) rent, lease, timeshare or otherwise
grant access to the software or its results or
sublicense, distribute or otherwise transfer the
software ... software, or any part thereof, or merge the
software with other software; (iv) reverse
engineer, decompile, disassemble or otherwise
attempt to derive the source code
treated software license and maintenance charges
received by the appellant of Rs. 12,32,61,326/- for
giving right to use of computer software ... does it provide the member firms the
source code or object code pertaining to the software
applications and it merely grants right
Application remains with assessee and end users have not
been given source code of the application which constitute technical
knowledge ... find force in the
contention of Ld. Counsel, that when no source code was shared
with the end users, said end user cannot be said
