Compensation received for terminating agreement was taxable as business income & not royalty income

INTERNATIONAL TAXATION: Where assessee, a US company, had entered into Network Participation Agreement with Citi Bank and granted non-exclusive right to Citi Bank for using know-how, technical process, etc., and received participation fee thereon which was offered as royalty in its regular return of income, but after termination of said agreement, assessee received compensation, which was claimed as business receipt, compensation received by assessee was to be treated only as business receipt in

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