Delhi High Court in Radio Today Broadcasting Ltd. [2015] 64 taxmann.com 164 (Delhi)on broadcasting radio programmes on FM channel held that for claiming additional depreciatin u/s 32(1)(iia) assessee must be engaged in the business of manufacture or production of any article or thing .'Manufacture' in the context of 'broadcast' it could encompass the processes of producing, recording, editing and making copies of the radio programme followed by its broadcasting. The activity of broadcasting, in the above context, would necessarily envisage all the above incidental activities which are nevertheless integral to the business of broadcasting.[para 32] The production of radio programmes, as explained by the Assessee, involved the processes of recording, editing and making copies prior to broadcasting. When the radio programmes is made there comes into existence a 'thing' which is intangible, and which can be transmitted and even sold by making copies. Therefore, it can definitely be stated that the radio programmes produced by the Assessee is 'thing', if not an 'article.'[para 27] For the purpose of additional depreciation u/s 32(1)(iia).Hence broadcast of radio programmes by FM channel qualifies for additional depreciation u/s 32(1)(iia). Comments: However High Court also held that if Assessee might be only 'broadcasting' the programmes produced by others , it would be arguable whether in the first place it could be said that the Assessee is "engaged in the business of manufacture or production of any article or thing"[Para 25] However , Under number of sections of Income tax law , manufacture has been defined to include recording of programmes on any disc, tape, perforated media or other information storage device. Further in Oracle Developers SC has held that mere commercial duplication of storage device with computer doftware is also manufacture. In case of Gramophone Co., SC has held that recording of sound cassettes is manufacture. Hence broadcasting without production might also tantamount to manufacture