software elsewhere, the software could not have
been re-issued to someone else by the customer, the software
could have been used only as integral ... right, title and interest in the software and related know. This
software cannot be used by the customer except for the
operation of the machine
software elsewhere, the software could
not have been re-issued to someone else by the customer, the software
could have been used only as integral ... right, title and interest in the software and
related know. This software cannot be used by the customer except for
the operation of the machine
equipment. On the ground that embedded software was shown
separately as customised software only to evade customs duty, the
adjudicating authorities, besides demanding differential duty ... agreement between HTCL and
the importer, the software was defined only as embedded
software; the software was imported through one port, and the
hardware through
attributed for the
supply of software emedded in the telecom equipment or software supplied
to the various customers in India should not be treated ... sometimes independently supplied to the
customers.
- The customer has been given the right to use the software
for the purpose of its business thereby assigning
group is involved in the execution of the
software development and coding of software service ("software services") outsourced ... product called 'Sapphire' to the domestic customers
and has undertaken customization of the software for these customers according to their
requirements
engaged in the business of design and development of
customized software applications. Apart from that, it also provided
technical support services during the relevant year ... software
development, software support, software project management
services, development of new application, maintenance or upgrading
or rework on any existing software projects/appliances, customer
support
software development segment, and (ii) software product
segment. The Assessee is a pure software services provider and not a
software product developer. According ... sold as packaged
products to customers. While implementing these standardized products,
customers may request the company to customize products or
reconfigure products to fit into
1285/Bang/2011
Page 22 of 62
only into software services. Similarly, as regards Ishir Infotech Ltd., the
Tribunal has considered the decision ... software development and product
development services. There is no information on the segmental
bifurcation of revenue from sale of product and software services
assessee's TP study report discloses that it is
providing customized software application development for its AE
21
ITA No.6200/Del/2012
within ... Product company owning software
26
ITA No.6200/Del/2012
products like Dxchange, Travel Solutions, Insurance Solutions,
Customer Appreciation, etc. Similar view has been taken
value of the Software and the right to use such software i.e Royalty towards such charges without which the software cannot be operated ... software which are developed from basic building blocks resulting in emergence of new software product. However in this case it is a customized software
