The High Court, following the ruling of the Supreme Court in Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT (2021) 432 ITR 471 (SC) answered in favour of the assessee the question whether the assessee was in default under section 201(1) of the Income-tax Act, 1961 for failure to deduct tax at source on payments in the nature of “royalty payments” as defined under Explanation 2 to section 9(1)(vi) of the Income-tax Act, 1961 and under the applicable Double Taxation Avoidance Agreements. SLP of Revenue dismissed giving liberty to the parties to rely upon the order if any passed in the review, disposed of the petition on the same terms leaving it open to the parties to initiate appropriate proceedings relying upon the order passed in review petition.(AY.2007-08 to 2012-13)