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22. Section 9(1)(vi) of the Act deals with taxation of income by way of `royalty'. It provides that the `royalty' will be taxed if it is payable in respect of any right, property or information used or services utilized. Explanation 2 gives the definition of CMA CGM Agencies India Pvt. Ltd., the term 'royalty'. Explanation 4, which is relevant for our purpose, reads as under:-

`For the removal of doubts, it is hereby clarified that the transfer of all or any rights in respect of any right, property or information includes and has always included transfer of all or any right for use or right to use a computer software (including granting of a licence) irrespective of the medium through which such right is transferred.'

23. On going through the mandate of the Explanation 4, which has been inserted by the Finance Act, 2012 w.r.e.f. 01-06-1976, it clearly emerges that rights in respect of any right, property or information shall include transfer of all or any right for use of a computer software including granting of a licence. The hitherto controversy about the payment for a copyrighted article whether amounting to Royalty or not has been set at rest with the Explanation 4 read with Explanation 5 to make it clear that even granting of a license of a computer software would constitute `Royalty'. Thus, there remains no issue about the taxability of income from computer software in any form as constituting royalty under the Act.