During the relevant period, the Assessee, a US-based company, made offshore sales of goods and offshore sales of software and related support services to its various customers in India. The AO failed to appreciate that though the Assessee had a Liaison Office (LO), the Assessee had closed its LO operations and no expat employees were engaged by the Assessee at the LO. Revenue could not place on record any material to show that even after the closure of LO operations, the assessee still had a business connection that could be termed as PE in India. Held, since no business activity was carried out by the assessee during the relevant period through LO, the assessee had no PE in India during the impugned AY and, hence, the question of attribution of profits to PE in India did not arise. Accordingly, it was further held that the amounts paid by resident Indian end-users/distributions to the Assessee, a non-resident computer software manufacturer/supplier, 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 thus, the same does not give rise to any income taxable in India. (AY. 2017-18 to 2020-21)