Held, that there was no specific finding by the lower authorities with regard to the licence agreement through which the assessee granted to the parties to use the software to say whether it was just the sale of software or royalty. The Assessing Officer was to consider the issue afresh in accordance with law in the light of judgment of the Supreme Court in Engineering Analysis Centre of Excellence P. Ltd. v. CIT (2021) 432 ITR 471 (SC). (AY. 2013-14)