Sec. 9 of Income Tax Act, 1961 – Income – Being aggrieved by the orders of the ITAT, revenue filed appeals on the question of royalty. Tribunal held that the amounts received by the assessee for the licence of its product, which was embedded software, were not royalties but rather business income. Tax appeal of the revenue dismissed as having no question of law. Revenue preferred SLP. Leave granted. – CIT Vs. BENTLY NEVADA LLC [2020] 270 TAXMAN 095 (SC)