Dismissing the appeal of the Revenue the Court held that   payments were made by assessee-company to non-resident-company which was computer software manufacturer/supplier for resale/use of computer software through distribution agreements, said payment did not amount to royalty for use of copyright in computer software, and same did not give rise to any income taxable in India. No substantial question of law.  Followed  CIT (LTU) 2024) 164 taxmann.com 10 /299 Taxman 488 (Bom)(HC) (AY. 2008-09,  2009-10)