Supply of software licence – supply of goods or services?

In re  SPSS South Asia Pvt. Ltd (GST AAR Karnataka) Does the supply of licenses for internet downloaded software fall within the ambit of Notification No.47/2017-Integrated Tax (Rate) dated 14th November 2017 and and Notification No.45/2017- Central Tax (Rate) dated 14.11.2017? The core issue before us to decide is the classification of the supply of software licence by the applicant i.e. whether it amounts to supply of goods or services. We observe that the software supplied by the applicant is a pre-developed or pre-designed software and made available through the use of encryption keys and...