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d) Training and education services: Education services are trainings that educate a customer how to get the most value from their products. Customers can take these classes via Online training, in-class or virtual instructor-

led training or certification for validated expertise.

5. The ld. Dispute Resolution Panel has given its finding on this as under:-

"5.5. Thus, it is clear that Software License services provided by the assessee having component of maintenance support and training, are medium to long term services. Hence, the Panel is of the view that software related services rendered by the assessee can be categorised as a process rather than sale of a product like literary work, piece of art, musical score etc. because of the inherent and intrinsic nature of these services, being a bouquet of services such as maintenance, infrastructure support, automatic upgradation, security concerns etc. on a continuous and ever evolving basis. As per Article 12(3) of the India-Singapore DTAA, to qualify as royalty for use of process, there should be 'use' or 'right to use' any process belonging to the payee and actual transfer of a process is not necessary. There is no requirement that there should be a transfer of processes embedded in the software such as Source Code or the Algorithm. Therefore, software license income of Rs. 14,28,71,004/- is liable to be treated as a process royalty under the treaty.