1. All these 19 appeals are assessee's appeals directed against the separate orders of ld. CIT(A)-XXX, New Delhi dated 10-06-2002 in 16 cases and 17-06-2002 in the remaining three cases i.e. ITA Nos. 3474/Del/2002 to 3476/Del/2002.

2. The issue involved in all these appeals is regarding the direction of the A.O. to the assessee for deducting tax at the rate of 15 per cent regarding payments to M/s. Subre Associates Inc. USA ('Sabre') and M/s. Abacus Distribution System Pte. Ltd., Singapore ('Abacus') for use of the software in or with the system that is owned or licensed, in whole or in part, directly or indirectly by these two parties or their predecessor for use by participants in conjunction with the system including any such software modified by the participants with the consent of these two parties. These systems were acquired by the assessee-company for using it for reservation and ticketing. In both these cases, it was held by the A.O. that the impugned payment by the assessee-company is unassessable in the hands of these non-residents as a royalty. Several payments were made by the assessee company to both these parties during assessment years 1997-98 and 1998