No disallowance for TDS default if revenue couldn't prove sum paid is in nature of royalty

IT/ILT : Where assessee engaged in manufacturing sophisticated chemicals, purchased from Germany, a catalyst in form of rings which was used in oxidation process of converting oxylene to pthalic anhydride, it did not amount to payment of royalty within meaning of Explanation to section 9(1)(vi) and, thus, assessee was not required to deduct tax at source while making said payment