whether the software is canned or
customized. In fact, the distinction between canned and customized software proceeds
from the admitted position that the Digital Content ... whether the software is canned or
customized. In fact, the distinction between canned and customized software proceeds
from the admitted position that the Digital Content
assessee explained that, the J-pack
J software
was not an accounting software but rather a custom--built inventory
software, meant to provide proper inventory ... approval
approval-basis to
customers or when the goods are returned by the customers or any inter-
inter
customer movement, these movements are recorded
assessee explained that, the J-pack
J software
was not an accounting software but rather a custom--built inventory
software, meant to provide proper inventory ... approval
approval-basis to
customers or when the goods are returned by the customers or any inter-
inter
customer movement, these movements are recorded
copyright, and thus, the payment received from licensing of such
customized software will not be royalty under the DTAA.
10. Without prejudice to the above ... copy right and thus, the
payment received from licensing of such customized software will
not be a royalty under the DTAA held as under
provided with the programs to
customize the Programs for Customers. Distributor may develop
and provide application or utility software for customers ... license key and the links are sent to the
customer. The customer downloads the software directly from
the US server (via the links) and installs
punching of number of software sets imported. Further, the software sets purchased or sold consist of large number of individual software which were bundled ... India. Thus, the software supplied by Diebold is a made to order software and hence there was delay in supply of software
punching of number of software sets imported. Further, the software sets purchased or sold consists of large number of individual software which were bundled ... India. Thus, the software supplied by Diebold is a made to order software and hence there was delay in supply of software.
17. We have
software,
which is a copyrighted article there is no right to reproduce or copy the
said software for commercial purposes although the said software ... right to use copyrighted software. Assessee did not get
any right in the copyright in the software. Copyright in the software continued to vest
with
Assistant Commissioner Of Income Tax, ... vs Cognizant Technology Solutions India ... on 16 May, 2025
आयकर
Cognizant Technology Solutions India ... vs The Assistant Commissioner Of ... on 16 May, 2025
आयकर अपीलीय
