The assessee placed advertisements on platforms of FB, AWS and RSC, making payments without TDS. AO treated assessee as assessee-in-default. CIT(A) confirmed. Tribunal, relying on Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT (2021) 432 ITR 471 (SC), held payments were not royalty under s. 9(1)(vi) or Art. 12(3) of DTAA. High Court dismissed Revenue’s appeal, holding the facilities were enabling in nature and copyright remained with service providers. Liberty granted to Department to seek review depending on SC’s outcome in Engineering Analysis.(AY. 2015-16, to 2017-18)