SFDC Ireland was not selling standard off-the-shelf and non-
customized downloadable software and that it was in fact offering a
comprehensive service experience ... SFDC products themselves are explained to be a software
which enables businesses to manage customers and prospect
9
PE
10
CRM
W.P.(C) 14636
consideration received by the assessee from various
customers on account of licensing of Customer
Relationship Management3 software is not royalty
income within the meaning ... follows:
SFDC Singapore shall provide access to customers based in India
to their (customers) data located on the Salesforce.com portal,
through its remote internet
that assessee is
not selling any standard off the shelf/non customized software but
instead is offering comprehensive services or solutions with the help ... 2024 at 21:24:30
selling standardized and non-customized software, it becomes
pertinent to note that Mr. Bhatia failed to make good that contention
engaged in providing
software testing and software quality assurance solutions by providing
licenses of its testing software to various entities and customers ... income in India
i. Income received from Software License
Tricentis GmbH offers testing software license to its customers
directly in India, primarily through purchase/subscriptions
property rights inherent in and
attached to the software product in favour of the licencee/customer is
what is contemplated by the Treaty. Merely authorising ... Assessee Company has
sold/licenced the software were allowed to make only one copy of the
software and associated support information for backup purposes with
property rights inherent in and
attached to the software product in favour of the
licencee/customer is what is contemplated by the
Treaty. Merely authorising ... Assessee Company has
sold/licenced the software were allowed to make
only one copy of the software and associated support
information for backup purposes with
property rights inherent in and
attached to the software product in favour of the
licencee/customer is what is contemplated by the Treaty.
Merely authorising ... Assessee Company has sold/licenced the
software were allowed to make only one copy of the
software and associated support information for backup
purposes with
Explanation 3.--For the purposes of this clause, ‗computer
software' means any computer programme recorded on any disc,
tape, perforated media or other information ... storage device and
includes any such programme or any customized electronic data;].
Explanation 4.--For the removal of doubts, it is hereby clarified
that
Explanation 3.--For the purposes of this clause, ‗computer
software' means any computer programme recorded on any disc,
tape, perforated media or other information ... storage device and
includes any such programme or any customized electronic data;].
Explanation 4.--For the removal of doubts, it is hereby clarified
that
Explanation 3.--For the purposes of this clause, ‗computer
software' means any computer programme recorded on any disc,
tape, perforated media or other information ... storage device and
includes any such programme or any customized electronic data;].
Explanation 4.--For the removal of doubts, it is hereby clarified
that
