Assessee-company was engaged in business of engineering and procurement assistance services .  It had purchased certain software licenses from Saipem SPA, Italy, which were used by assessee for providing services to customers for various support functions in accounting, reporting, etc. . Assessing Officer made disallowance of  payment by invoking provisions of section 40(a)(i) as assessee had not deducted tax at source as required under section 195 while making payment to Saipem SPA, Italy, by holding that aforesaid payments were royalty payment under section 9(1)(vi) and article 13(3) . CIT (A) deleted the addition .  On appeal by the revenue  the Tribunal held that  assessee had made payments to Saipem SPA, Italy towards software licenses/purchase of software, a personal, non-exclusive, non-transferable license with a right to make unlimited copies, however, said software can only be used for internal purposes . Tribunal  further held that  grant of non-exclusive non-transferable license in computer software with no right to sub-lease or transfer would fall within purview of Royalty both under DTAA as well under section 9(1)(vi) and would be chargeable to income-tax under provisions of Act .  Followed CIT v. Synopsis International Old Ltd (2013) 212 Taxman 454 ( Karn) (HC), Zylog Systems Ltd v. ITO (IT ) 415 ITR 311 ( Mad ) (HC)  (AY . 2014-15)