In the result, all the appeals of assessee are allowed
Bench: Ms. Sushma Chowla, Jm & Shri Anil Chaturvedi, Am आयकर अपीऱ सं. / Ita Nos.905 & 906/Pun/2015 यििाारण वषा / Assessment Years :2007-08 & 2008-09
115A(1A) of the Act was on the Statute and the said section already was there, so definition of ‘royalty’ was covered. The amendment brought in to section 9(1)(vi) of the Act was clarificatory in nature, for removal of doubts and cannot be said to be prospective application. He then pointed out that if it is literary work