Assessee-company, a tax resident of UK, was engaged in providing global business news and information services to organizations worldwide. It entered into an agreement with its group company, DJCIPL, for distribution of its financial products in Indian market and, thereby, received consideration.  Assessing Officer treated same as ‘royalty’ under provisions of Act as well as India-UK DTAA as payment was for use of copyright in literary work; use of information concerning commercial, scientific knowledge, experience and skill; and use or right to use equipment or process. Held that payment received by assessee merely for use of database and not for use or right to use any equipment, was not ‘royalty’ under article 13 of India-UK DTAA.  (AY. 2015-16)