right to duplicate and distribute Oracle software in India.
3.2 OIPL provides software licences to customers in India on payment of a licence ... Media pack was not supplied to the customers in this model.
(ii) EPD +: The customers downloaded Oracle software electronically. In addition, the customers were provided
India. While the hardware is sold,
the software is licensed. With respect to software, the customer is granted
partial rights permitting the use of software ... software always remains with Aspect Software Inc.
(e) The assesee's contention that software and hardware are co-joint and
software and hardware
card lifecycle management software; merchant life cycle
management software; wholesale payment processing software for NEFT and
RTGS payments; payments initiation software through various channels like ... payments switch software (such as
BASE24); Interchange software including VISA, MasterCard, NPCI; bill
payments software; fraud monitoring software; and payments infrastructure
monitoring software
charges,
interest charges, expenses reimbursement within the group
and fees received for software development and sport
services. The AO referred the matter ... ended on
31.03.2007. Accordingly, the fees received by the assessee
for software customization and sport services run to its
associate enterprises amounting
based on these, the Plaintiffs make various customized
softwares for their clients. Such softwares include the software algorithms of
'CRATOR' and 'SEEQUER ... remaining eleven modules were developed and customized using the Plaintiffs'
existing Source Code Library. (The customized unique software thus prepared
for the Defendant
technical services. The assessee has only rendered
software development services or exported software to its
customers outside India and has not rendered any technical
services ... payer purchased Software called "Small World software" from the
Dutch company and bundled with its own software and thus
customized it and sold
household provisions located in select
BPCL Petrol Pumps for which a customized software was to be supplied by
the assessee, which in turn has been ... supplying
customize business application software and for independent testing of the
software before export to customers, the expenditure was incurred has not
been rebutted
specific
set of activities involved in the business use of its customers. Software also
made available the process to its customers, who used ... with respect to whether consideration
paid towards supply of software along with hardware - rather software
embedded in the hardware amounted to royalty. After noticing several
rights are given to the assessee
by the software suppliers, as to whether the software were customized for
the use of assessee, the nature ... light of
the fact that if the assessee had received the customized software from
the foreign suppliers then it could be termed as transfer
system infrastructure
software products of CAII(US),developing software that can generally be deployed "öut of
box" or with customer/industry-specific adaptations ... upgrades and enhancements of software purchased/licensed but also the
maintenance of the software and unspecified future software products i.e.new release
