Aassessee, a US based company, purchased certain number of licenses of different software and charged, inter alia, Indian entity for licenses issued, in absence of PE in India, software license fee would not be taxable as business profits.  Tribunal also held that since licensors permitted assessee only to install, operate and use their software products to extent of copies purchased by it, without any right to copy same, it could not have transferred anything more than that to its entities globally including India and therefore, there could be no question of treating amount received from Indian entity on transfer of copyrighted articles as royalty in hands of assessee within meaning of article 12(3). (AY. 2016-17)