2007 (9) TMI 131

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....al, Delhi Bench "E" in ITA No.1070 (Del) 2005 relevant for the assessment year 2001-2002. 2. The Revenue has raised two issues before us. The first issue relates to depreciation claimed by the assessee on the decoders owned by it but given on loan to various cable operators. 3. It appears that the assessee owns decoders for decoding television signals. Some of the decoders are sold on deferr....

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....ble operators. This has rightly been found on facts to be incorrect by the Tribunal. 6. It is contended by learned counsel for the Revenue that the decoders for which depreciation is claimed are not used for the purposes of the business of the assessee. We are unable to appreciate this contention. The assessee is engaged in the business of providing satellite signals, distribution of satellite ....

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....to the conclusion that the amounts on which the TDS was deducted related to the income of the principal of the assessee and, therefore, the assessee was not entitled to the tax deducted at source. 9. The Tribunal, on the contrary, held that the assessee had offered a sum of Rs. 22.70 crores as income under the head "channel subscription licence fees". This amount included various payments made ....