Held that the amounts paid by Indian end-users/distributors to assessee, non resident computer software manufacturers/suppliers, as consideration for resale/use of computer software through EULAs/distribution agreements, is not payment of royalty for use of copyright in computer software, and same does not give rise to any income taxable in India.  Foreign company, earned income from rendering of standard automated services to Indian customers and Assessing Officer treated same as technical services, since Tax Authorities did not examine whether technical services involved human intervention and moreover there was lack of examination of issue by taking into account relevant evidence and opinion of expert, issue required restoration to files of Assessing Officer to decide issue afresh. (AY. 2016-17)