Assessee, a Foreign company received royalty pursuant to various agreements entered into before or after 1-6-2005. Assessing Officer made assessment by levying tax at rate of 15 per cent. Tribunal held that rates prevailing during different periods under DTAA and under section 115A which were more beneficial to assessee, had to be applied. On appeal by revenue, high Court affirmed the order of the Tribunal. (AY. 2007-08)