Assessee was a company incorporated in Ireland and during year under consideration, it was in receipt of certain sum towards Sale of Software from its Indian Distributors. AO assessed the receipt as royalty. On appeal the Tribunal held that distinction between transfer of a copyright and transfer of a copyrighted product is prominent and there being no transfer of copyright in computer software by assessee to its customers, receipt from sale of software would not be in nature of Royalty as per article 12. AY.2014-15)