That the Tribunal in the assessee’s case for an earlier year on similar facts had held that the receipts on hire of vessel on time charter basis were not in the nature of royalty, that the consideration received by the assessee was not on account of use or right to use the vessel, which in fact had throughout remained with the assessee and was never transferred to the charterer, that though the vessel was used by the assessee for rendering services to the charterer it was not used by the charterer on an independent basis. The Tribunal held that in a case where the control of the equipment throughout had remained with the assessee and did not get transferred to the charterer, the consideration therein received could not be brought within the realm of the definition of the term “royalty”. Therefore, the receipts on hire of vessel on a time charter basis were not royalty and the addition with respect to the receipts in question were to be deleted. That the receipts were intricately linked to the chartering income. Thus the addition on account of reimbursement of expenses is   deleted.(AY. 2020-21)