High Court held that since the copyright in the application was never transferred nor vested in the subscriber, the fees were not assessable under section 9(1)(vi) of the Act  and that since the customer was merely accorded access to the application and it was the subscriber which thereafter input the requisite data and took advantage of the analytical attributes of the software, this would clearly not fall within the ambit of article 12(4)(b) of the Double Taxation Avoidance Agreement between Singapore and India, and that therefore, the amount was not assessable in India. SLP of revenue dismissed.  (AY. 2011-12 to 2017-18)