Held that the assessee had sold copyrighted article and not the copyright. Accordingly, the amount received by the assessee from sale of software and provision of software related services could not be treated as royalty under article 12(3) of the Double Taxation Avoidance Agreement between India and Singapore. The Tribunal also held that the Assessing Officer had not brought any cogent material on record to demonstrate that while providing the software related maintenance service, the assessee had made available any technical knowledge, know-how, or skill so as to enable the recipient of such service to use it independently in exclusion of the assessee. As the conditions of article 12(4)(b) of the Agreement were not satisfied, the amount received could not be treated as “fees for technical services”. The addition made was to be deleted. The Assessing Officer was directed to compute the tax liability strictly in terms of the provisions of the Agreement. (AY.2014-15)