Assessee provides  to facilitate the registration and transfer of generic top-level domains, such as.com,.net, org. and info-Besides this, the assessee also provides the same service for country code top-level domains, which includes us,.ca, mx, fr, it, de,.es.-Accreditation Agreement in no uncertain terms, establishes that the assessee has given up exclusive ownership or use of data elements listed in sub-ss. 3.2.1.1 and 3.2.1.3 for all registered names submitted by it to the registry database or sponsored by it in each gTLD for which it is accredited. Clause 3.5 of the Accreditation Agreement clearly establishes that the assessee who acts as a registrar and, in that capacity, provides domain registration services to its customers does not have any proprietorship rights in the domain name. Therefore, the submission advanced on behalf of the assessee, i.e., that since it is not the domain name’s owner, it cannot confer the right to use or transfer the right to use the domain name to another person/entity, is  acceptance. Therefore, the fee received by the assessee for registration of domain names of third parties, i.e., its customers, cannot be treated as royalty. Appeal of assessee is allowed.  (AY.  2013-14 to 2015-16)