Assessee, a non-resident company, received consideration for supply of software to Reliance and claimed same to be business income not taxable in India in absence of any permanent establishment in India.  Assessing Officer held  that consideration received by assessee was towards a license to use software and, thus, taxable as royalty under section 9(1)(vi) hence liable to deduct tax at source. CIT(A) allowed the appeal of the assessee. On appeal Tribunal affirmed the order of the CIT(A). On appeal the Court held that the issue is    covered by authoritative pronouncement of Supreme Court in case of Engineering Analysis Centre of Excellence (P.) Ltd. v. CIT(2021) 281 Taxman 19/ 432 ITR 471 (SC) wherein it was held that amounts paid by resident Indian end-users/distributors to non-resident computer software manufacturers/suppliers, as consideration for resale/use of computer software through EULAs/distribution agreements, was not payment of royalty for use of copyright in computer software and that same did not give rise to any income taxable India. Order of Tribunal is affirmed. No substantial question. of law. (AY.  2003-04, 2004-05, 2006-07  2010-11  2010-11)