Assessee, a US-company, was one of accredited domain name registrar of world’s largest Internet Corporation for Assigned Names and Numbers (ICANN). It received certain amount towards domain name registration services, which was not offered to tax Assessing Officer  held that  assessee acted as channel between customers and ICANN for domain name registration and assessee also enabled customers to get their names registered with ICANN for which it charged fee from them and concluded that amount received was in nature of royalty as per section 9(1)(vi) read with section 115A. Tribunal held that  since assessee had transferred right to use domain name, which was in nature of trademark, then consideration received by assessee for transferring such right would qualify as royalty under Explanation 2 to section 9(1)(vi) of the Act. Tribunal also held that   consideration received  from web hosting services being ancillary to domain name registration services, had to be treated as FTS. (AY. 2015-16)