applicable, its licensors and/or
suppliers.
5. 2 Ownership of Derivative works Works and Software Embodiments.
Google India shall keep Google Ireland promptly informed ... Google
India's development of any Derivative works Works and Software
Embodiments and hereby irrevocably agrees that all such Derivative works
Works and Software
cannot copy, modify or create or derivate
work or reverse engineer any part of the software/platform through
which it inputs data and retrieves processed ... cannot copy, modify or create or derivate work or reverse engineer any
part of the software/platform through which it inputs data and retrieves
processed
towards purchase of software. As a result of the
outlay, the assessee secured a license to use the software. The
license was available ... prevented from modifying or duplicating the software. It could
not decompile or disassemble the software. No derivative works
could be created. The assessee was permitted
language or otherwise modify, adapt, alter,
translate, or create derivative work from the
software; (ii) rent, lease, timeshare or otherwise
grant access ... software or its results or
sublicense, distribute or otherwise transfer the
software to any third party or (iii) alter, modify,
reproduce or create derivative works
Tata Consultancy Serrvices Limited, ... vs Dcit-1, Mumbai on 15 September, 2023
1
ITA 5199
United States,
governing royalty with regard to acquisition of computer software.
In the said regulations, the US IRS have held that payments made
for acquisition ... shall not modify, alter, change,
adapt or create derivative works based upon such
software and tools, or any part thereof; (b) shall not
sell, assign
Software, and (ii) each Update made available as part of
Maintenance Service contracted for such Software license or Juniper Platform (for
Embedded Software Licenses ... separate any part of or embedded within, or
create derivative works based on, the Software, except solely to the most minimal
extent required
licensed Software to support any third party processing ;
(b) cause or permit decompilation, disassembly or reverse
engineering of the Software, in whole or in part ... Software
by persons other than Buyer's employees, consultants or
implementors of the Software;
(d) write or develop derivative work (meaning any new code
M/S Infosys Limited , Bangalore vs Assistant Commissioner Of Income Tax ... on 31 January, 2023
export of
computer software where the business entity provides
technical services outside India in connection with
developments or production of computer software.
Hence, the aspect ... Section 10A under the head
of 'Profits' derived from export of computer software or
under the head of 'rendering technical services outside
