Held that  for the assessment years 2009-10, 2010-11, 2012-13 and 2013-14, the Tribunal having held that the distribution revenue earned by the assessee could not be taxed at royalty, albeit as business income, since the assessee had already offered income as business income in terms of the mutual agreement procedure, the income declared by the assessee in accordance with the mutual agreement procedure had to be accepted, the Assessing Officer was to delete the addition. Tribunal also held that the revenue derived from the two companies was not taxable in India in terms of section 9 of the Act and since the income did not form part of the total income of the assessee the credit for tax deducted at source was denied. The assessee could claim the credit for the tax deducted at source in the country in which the related income was offered to tax. There was no reason to interfere. (AY. 2014-15)