While considering the issue relating to tax deduction at source , levy of interest , penalty ,the court held that  the Tribunal being the fact finding authority ought to look into the facts before ordering a remand on the basis of the directions issued by the Supreme Court. The Tribunal should look into it and after verification, pass appropriate orders in terms of the directions of the Supreme Court in Hindustan Coca Cola Beverage P. Ltd [2007] 293 ITR 226 (SC)  . With respect to the payments of uplink charges and backhaul link usage charges, the Tribunal should examine an expert as produced by the assessee and the Department shall be permitted to cross examine the expert and produce any further evidence or witnesses on its behalf. The issue should be decided on the basis of the decision in Bharti Cellular Ltd. There could be no liability on hire charges and camera rental payments for the financial years 2003-04 to 2006-07.  On the tax deduction from payment of contracts, commission, rent, salary, professional and consultancy charges for the financial years 2003-04 to 2007-08, the assessee should produce sufficient evidence before the Tribunal as laid down in Circular No. 275/201/95-IT(B), dated January 29, 1997.  Referred CIT v. Eli Lilly and Co. (India) P. Ltd. [2009] 312 ITR 225 (SC)  a CIT v. Bharti Cellular Ltd. [2011] 330 ITR 239 (SC).