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    <title>Service Tax on Software - Tax on goods versus tax on service - constitutional validity - legislative competence of the central government</title>
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    <description>Parliament has legislative competence to tax software services under its residuary power; whether software is &#039;goods&#039; depends on attributes like utility, capability of being bought and sold, and transferability, and many transactions governed by end-user licences transfer only a right to use while copyright is retained by the developer. Customised software and downloadable access without physical media may not constitute goods. The characterisation of any transaction as sale or service depends on its specific terms and must be assessed individually when tax demands are raised.</description>
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