The assessee made payments to foreign companies towards purchase of licensed software. The Assessing Officer treated the payments as “royalty” under section 9(1)(vi). The Commissioner (Appeals) and the Tribunal confirmed. On further appeal, the High Court, following Engineering Analysis Centre of Excellence Pvt. Ltd. v. CIT (2021) 432 ITR 471 (SC); (2022) 3 SCC 321, held that such payments do not constitute royalty under section 9(1)(vi). Liberty was granted to the Department to seek review if the review petition in Engineering Analysis succeeds. Order quashed to that extent.