Assessee, a media broadcasting and telecasting company entered into an up-linking service agreement with a company for up-linking and bandwidth services and also entered into another agreement for air time service charges.  Assessee deducted tax at source under section 194C while making payment to said companies for services rendered as per agreements.  Assessing Officer held that payments were in nature of fees for professional and technical services and therefore, should be covered under section 194J. Tribunal held that since deductees simply carried out a contractual work of up-linking and broadcasting programmes made or produced by assessee in electronic media by permitting assessee to avail benefit of requisite electronic set up against payment of a fee as long as contract subsisted, facilities provided by deductees did not amount to providing ‘technical services’ and, hence, payments could not be termed as ‘fee for technical services’; thus section 194J was not attracted. On appeal by revenue affirming the order of the Appellate Tribunal held that definition of ‘work’ under section 194C is inclusive and specifically includes broadcasting and telecasting and, therefore, assessee had rightly deducted tax at source under section 194C. (AY. 2010-11)