S. 115A : Foreign companies – Tax – Royalty –Entitled to adopt rate of tax payable on royalty income in respect of both agreements entered into before 1-6-2005 as on or after 1-6-2005 as per provisions of section 115A(1)(b) or provisions of Article 12 of Indo-US DTAA, which were more beneficial- DTAA -India -USA [ S.90 , Art , 12 ]