2020 (1) TMI 1594

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... principal to principal relationship and not that of principal to agent. The Tribunal followed the decision in the case of Bharati Airtel Ltd. [ 2014 (12) TMI 642 - KARNATAKA HIGH COURT ] and held that the sale of SIM cards/recharge coupons at discounted rate to the distributors was not commission and not liable for deduction of TDS under Section 194H. No substantial question of law. - INCOME TAX .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... not require deduction of tax under Section 194H of the Income Tax Act ? (b) Whether on the facts and in the circumstances of the case and in law, the Hon ble Income Tax Appellate Tribunal erred in setting aside the case to the Assessing Officer ? 5. The Tribunal noted the observations of the Assessing Officer that the discount allowed to the distributors by the Respondent assessee company .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... ding against the Appellant Revenue observed thus :- 3. Having heard the learned Counsel for the parties and having perused the documents on record, we do not find any error in the view of the Tribunal. The Tribunal, as noted, besides holding that the Commissioner s order setting aside the order passed under Section 201 was not carried in appeal, had also independently examined the nature of .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X