Assessee was a company incorporated in Sweden.  During year, assessee was in receipt of certain sum towards sale of software products from its Indian distributors who further sold same to end customers in India.  Assessing Officer held that sale of software products by assessee was in nature of transfer of copyright and, therefore, consideration received for same was taxable in hands of assessee as royalty under section 9(i)(vi) as well as under article 12 of India-Sweden DTAA. CIT (A) affirmed the order of the Assessing Officer. On appeal the Tribunal held that sale of software products by assessee to its Indian distributors for further sale to end users was not in nature of transfer of copyright and, therefore, consideration received by assessee for sale of software was not taxable in hands of assessee as royalty’ under provision of section 9(1)(vi) and article 12 of India-Sweden DTAA.  (AY. 2014-15)