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A Process is a series of actions or steps towards achieving a particular end, whereas a Computer program means a set of instructions expressed in words, codes, schemes or in any other form, including a machine readable medium, capable of causing a computer to perform a particular function to achieve a particular result i.e a Computer Software is a set of computer programs that define a series of actions or steps that must be taken by the Computer Hardware to achieve the desired result. The Computer Software Program therefore defines a process to achieve the result through a set of instructions used to control the elements of hardware. The program is written in a language which can be comprehended by human beings, this is called source code. But when this set of instructions is converted into executable files i.e machine language, they become non- understandable by humans. It is these machine language executables which are provided to the user in form of Computer Software and not the set of instructions expressed in words which could be understood by humans. A software program in machine language or in form of executable files forms a sort of black box which accepts inputs and accordingly generates output by controlling the machine hardware. How the input commands are processed is not known unless one has access to the source code. Thus a software program basically acts as a secret process which processes the input commands of the user. The payment made for right to use of such secret process would definitely take form of 'royalty' as the definition of Royalty in DTAA as well as the Income Tax Act encompasses the right to use of a secret process.