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14. It was held that the SAP solution softwares are basically classifiable as a "process" or plan and the consideration of the same is certainly consideration for a process as included in the definition of Royalty in the DTAA. The term "process" used here is not in the contex t of the manner of writing a computer program. It was held that the Co-ordinate Bench of Trib unal had discussed the classification of "process" related to software royalty by stating the source code was not transferred therefore there is no royalty as the process was not shared , but what is required to be seen is that the software solution provided by the Company is a restructure of the process of managing operations or doing work in a particular manner. It is that "process" which has been shared throug h a software implementation. An example is a SAP implementation in an entity, which is a business solution and lays down a specific manner of execution of activities. Or take the case of a Supply Chain Management Solution given by a professional company to ITA Nos. 7259 & 7260/Del/2019 Mitsubishi Electric India Pvt. Ltd.