The Assessing Officer disallowed payments made for purchase of software on the ground that tax had not been deducted at source. The Tribunal held that the assessee had acquired only the right to use copyrighted articles and not any copyright. The payments did not constitute royalty chargeable to tax in India and, therefore, no tax was deductible under section 195. The disallowance under section 40(a)(i) was deleted. (AY. 2014-15).