25 & 26-ITXA-20-19.DOC Urmila Ingale IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO. 20 OF 2019 WITH INCOME TAX APPEAL NO. 47 OF 2019 Pr.Commissioner of Income Tax-16 …Appellant Versus Lamhas Satellite Services Limited …Respondent Mr.P.A. Narayanan, for the Appellant. Mr. B.V. Jhaveri a/w Ms.Bhargavi Raval, for the Respondent. CORAM: SUMAN SHYAM & GAUTAM A. ANKHAD, JJ. DATED: 28th SEPTEMBER 2026 PC:- 1. Mr. Narayanan, learned counsel appearing for the Appellant- Revenue in both the Appeals submits that the core issue involved in both these Appeals pertains to the question as to whether deduction is to be made at the rate of 10% or at the lesser rate of 2% as has been held by the learned Tribunal. 2. By referring to the decisions of this Court in the cases of (i) Principal Commissioner of Income Tax Vs. Media Worldwide Ltd.1 ; 1 [2026] 185 taxmann.com 997 URMILA PRAMOD INGALE Digitally signed by URMILA PRAMOD INGALE Date: 2026.09.30 15:37:02 +0530 25 & 26-ITXA-20-19.DOC (ii) Principal Commissioner of Income Tax Vs. Morgan Stanley India Capital Pvt. Ltd2 ; and (iii) Principal Commissioner of Income Tax-16 Vs. Zee Entertainment Enterprises Ltd.3 , Mr. Narayanan submits that aforesaid question of law have already been answered by this Court, in the aforementioned decisions, against the Revenue by holding that deduction is required to be made but at a lesser rate. 3. In view of above, Mr. Narayanan submits that the substantial questions of law projected in these Appeals would stand answered by the aforementioned decisions of this Court. The said proposition has not been controverted by Mr. Jhaveri, learned counsel for the Respondent in both the Appeals. 4. After going through the record, we are also of the view that nothing further survives for adjudication in these Appeals in the light of law laid down by this Court in the Principal Commissioner of Income Tax Vs. Media Worldwide Ltd (supra), Principal Commissioner of Income Tax Vs. Morgan Stanley India Capital Pvt. Ltd (supra) & in Principal Commissioner of Income Tax-16 Vs. Zee Entertainment Enterprises Ltd. (supra). The Appeals are, therefore, disposed of. (GAUTAM A. ANKHAD, J.) (SUMAN SHYAM, J.) { 2 [2025] 177 taxmann.com 699 3 [2026] 187 taxmann. Com 703