Held, dismissing the appeals, that the issue of taxability of software receipts was no longer res integra since the Supreme Court in Engineering Analysis Centre Of Excellence Pvt. Ltd. v. CIT  [2021] 432 ITR 471 (SC)had held that the amounts paid by resident Indian end-users or distributors to non-resident computer software manufacturers or suppliers, as consideration for the resale or use of the computer software through end-user licence agreements or distribution agreements, was not royalty under section 9(1)(vi) of the Income-tax Act, 1961 for the use of copyright in the computer software, and did not give rise to any income taxable in India, as a result of which the persons referred to in section 195 were not liable to deduct any tax thereunder. No question of law arose.