Held that  sale of off-shelf software by assessee-company to its AE was merely a sale of copyrighted article and had not resulted in transfer of any right in relation to a ‘copyright’ embedded in software, amount received by assessee from its AE on account of sale of software/license charges was not royalty under article 12(3) and as per section 9(1)(vi).  (AY. 2010-11)