Payer not liable for TDS default due to amendments made in definition of royalty at later stage with

IT : Where Assessing Officer on basis of amendments introduced in section 9(1)(vi) with retrospective effect held that assessee was liable to deduct tax at source from licence fee paid for use of softwares and disallowed payments by invoking provisions of section 40(a)(ia), assessee could not be held responsible for violation of TDS provisions on basis of subsequent amendments introduced in section 9(1)(vi)