this, it was contended that the payment was
towards purchase of off-shelf software which is not chargeable to tax in
the hands of software ... make use of the copyright software contained in the said software,
which is purchased off the shelf or imported as shrink wrapped software
that 'MFG Pro Software'
purchased by the assessee is an accounting software and is available off the
shelf. QAD Singapore Pvt. Ltd. supplied ... market items and are
available off the shelf. At the time of sale of such off the shelf software
embedded diskettes or CD-ROMs
According to the assessee the software licensed to Reliance under
the software licence agreement is an 'off the shelf'/Shrink Wrapped'
software ... submits
that the software licensed to Reliance under the Software license
agreement is off-the-shelf software. The software products provided under
the said agreement
received by the Appellant towards sale of 'off-the shelf software are in the nature of
'Royalty' as per the provisions ... received by the Appellant towards sale of 'off-the shelf software are in the nature of
'Royalty' under Article
received by the Appellant towards sale of 'off-the shelf software are in
the nature of 'Royalty' as per the provisions ... received by the Appellant towards sale of 'off-the shelf software are in
the nature of 'Royalty' under the India-Finland
individual clients, and
"Branded software" or "off-the-shelf software" which is standardised
and marketed as such. When off-the-shelf ... said software purchased by the appellant company is "off the
shelf" software/Shrink wrapped Software. The appellant company is
authorized to use only
individual clients, and "Branded software" or "off-the-shelf software"
which is standardised and marketed as such. When off-the-shelf ... said software purchased by the appellant company is "off the shelf"
software/Shrink wrapped Software. The appellant company is authorized to use
only
aside.
2. Treatment of income from sale of off-the-shelf software as
`royalty'.
a. The AO and the DRP erred ... received from Indian customers towards
sale of shrink wrapped and off-the shelf software as 'royalty'
under Section
specific application software development and support services generally known as software consultancy services.
3. According to revisionist, computer software sold off the shelf also called ... made software (for sake of convenience hereinafter referred to as 'uncanned software') and also sell Computer Software Packages off the shelf (hereinafter referred
individual clients, and
"Branded software" or "off-the-shelf software" which is standardised
and marketed as such. When off-the-shelf ... said software purchased by the appellant company is "off the
shelf" software/Shrink wrapped Software. The appellant company is
authorized to use only
