Held that the assessee could not own copyright over the software. The products sold by the assessee were ready to use off the shelf or shrink wrapped software, which were nothing but copyrighted articles. The assessee was merely a trader of software. Thus, has no domain or ownership over the software. When the assessee did not have any ownership over the software sold, it could not have transferred the right to use the copyright in the software to the distributors or customers in India. Hence, this consideration received from sale of software could not be treated as royalty. (AY. 2017-18)