Dismissing the appeals of the Revenue the Court held that  the issue of taxability of software receipts was no longer res integra since the Supreme Court in Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT (2021) 432 ITR 471 (SC) had held that the amounts paid by resident Indian end-users or distributors to non-resident computer software manufacturers or suppliers, as consideration for the resale or use of the computer software through end-user licence agreements or distribution agreements, was not payment of royalty under section 9(1)(vi) for the use of copyright in the computer software. No question of law arose. (AY. 1999-2000 to 2001-02)