Dismissing the appeal of the revenue the Court held that the Tribunal was right in holding that royalty income received under an agreement entered into before June 1, 2005 and royalty income received under an agreement entered into on or after that date was from the same source and as such the assessee could apply section 115A or the Double Taxation Avoidance Agreement separately for one source of income covered by different agreements. (AY. 2007-08, 2008-09, 2013-14)