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TMI Blog2020 (1) TMI 1652X X X X Extracts X X X X X X X X Extracts X X X X ..... ion - HELD THAT:- Tribunal followed the decision 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 therefore not liable for deduction of the TDS u/s194H. The Tribunal noted that there was no decision of this Court on this issue on that date. Also decided in M/s. R ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... substantial questions of law :- (a) Whether on the facts and circumstances of the case and in law, the Hon ble Income Tax Appellate Tribunal erred in holding the discount given by the assessee to its distributors on prepaid SIM Cards does 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er passed in Income Tax Appeal No. 702 of 2017 subsequently in the case of Pr. Commissioner of Income Tax-8 vs. M/s. Reliance Communications Infrastructure Ltd ., where same issue arose for the consideration of this Court. The Division Bench of this Court while holding against the Appellant Revenue observed thus :- 3. Having heard the learned Counsel for the parties and having perused the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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