Section 40(a)(ia) of the Income Tax Act, 1961 — Business Disallowance — Payment made by the assessee for purchase of off the shelf software was not in realm of "royalty" and as of definition of royalty had not been amended under the DTAA,the provisions of DTAA being more beneficial were to be applied and there was no requirement to deduct tax at source out of such payments, thus, the disallowance made under section 40(a)(ia) was not warranted— Eaton Technologies P Ltd v Deputy Commissioner of income tax [2019] 75 ITR (trib) 675 (Pune)