Assessee, an American company, entered into various transactions with its Indian subsidiary CIS. It procured services of telecom service providers and provided same to its Indian subsidiary CIS and received link charges from CIS. There was no right to use, either to assessee or to CIS.Assessee had merely procured a service and provided same to CIS. No part of equipment was leased out to CIS. Even otherwise, payment was in nature of reimbursement of expenses and accordingly not taxable in hands of assessee. Therefore, payments did not constitute royalty under provisions of article 12 of  DTAA between India and USA. (AY. 2014-15)