Dismissing the appeal of the Revenue High Court  held that amount paid by resident Indian end-user/distributors to 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 it does not give rise to any income taxable in India.SLP of revenue dismissed  followed  Engineering Analysis Centre of Excellence (P.) Ltd. v. CIT (2021) 432 ITR 471 / 281 Taxman 19 (SC).  Court also held taht once a judgment is passed by a court following another judgment and subsequently the latter judgment is overruled on a question of law, it cannot have an effect of reopening or reviving the former judgment passed following the overruled judgment nor can the same be reviewed. The Explanation to rule 1 of Order XLVII of the Code of Civil Procedure, 1908 is in the nature of an exception. In other words, the Explanation being in the nature of a proviso qualifies or is an exception to what is stated in rule 1 of Order XLVII of the Code, which states the grounds for seeking a review. Hence, the object and intendment of the Explanation must be given its full effect. The object and purpose of the Explanation can be related to the three maxims : nemo debet bis vexari pro una et eadem causa (no man should be vexed twice for the same cause), interest reipublicae ut sit finis litium (it is in the interest of the State that there should be an end to a litigation), and res judicata pro veritate occipitur (a judicial decision must be accepted as correct). There must be an end to litigation, otherwise, the rights of persons would be in an endless confusion and fluidity and justice would suffer. This is against public policy and not in the interest of the State. (AY. 2006-07)