Held that customers were neither in possession of any equipment nor had any control over equipment used by assessee and assessee was sole bearer of risks in relation to said equipment. Since the  assessee was merely making an entrepreneurial use of its own equipment to provide services, it could not be said that customers had a right to use process, if any, involved or applied by assessee in its capacity as a service provider. Accordingly the  amount received by assessee from its customers in India as consideration for provision of a service could not be characterized as royalty for use or right to use of a process.  (AY. 2017-18)