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"13. We have briefly discussed supra two business models in this line of business and found that whereas under the first model, TV channel approaches DTH/cable operators for telecasting its programs on its own behalf, under the second model, right to use in programs are transferred by TV channel to DTH/cable operators for value. In such later case, revenue from ultimate viewership goes to the DTH/Cable operators and TV Channel ends up by receiving consideration from DTH/cable operator for transfer of rights in its programs. While the third step, namely, telecasting and broadcasting of TV programs under the first business model is done by DTH/Cable operators for and on behalf of TV channels, and under the second business model is done by DTH/cable operators for and on their own behalf and not the TV channels. Whereas under the first business model, payment is made by TV channel to DTH/cable operators for 'broadcasting and telecasting' their TV programs, which is covered u/s 194C, under the second business model, payment is made by DTH/cable operators to TV Channel for transfer of IPRs in programs to be used by DTH/cable operators in 'connection with television', which is covered under clause (v) of Explanation 2 to section 9(1)(vi) requiring deduction of tax at source u/s 194J of the Act. The case under consideration clearly falls under the second business model. In our considered opinion, the authorities below were fully I.T.A. No. 1162/Hyd/2014 :- 19 -: S. Kalpana Vs ITO, justified in holding the applicability of the provisions of section 194J of the Act.