Assessee is in business of manufacture of motorized two wheelers and three and four-wheeled light goods transport vehicles. It received royalty income and technical fees for services rendered in India to its AEs.It entered into two agreements with its AE. Assessing Officer after considering both agreements, concluded that second agreement was only an extension of first agreement and, therefore, tax rate applicable would be 20 per cent and not 10.56 per cent. Tribunal held that there was difference between two agreements and also law as prevailing and old agreement provided that trademarks to be used by assessee were only restricted to Ape 501 and Ape 601, whereas, as per new agreement assessee had provided license to manufacture and sell vehicles under name of Ape, which encompassed all kinds of vehicle.Tribunal also held that territory which was covered under old agreement was different from territory that was covered under new agreement and thus, second agreement was not an extension of earlier agreement. Dismissing the appeal of the Revenue the Court held that new agreement and not extension of the licence and Technical Assistance agreement tax rate is 10.56% under section 115A instead of 20 % under the India-Italy DTAA. No substantial question of law.