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2024 (11) TMI 507

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..... lant(s)/revenue submits the issue is no more res integra, in view of the judgment passed by Bharti Cellular Limited (Now Bharti Airtel Limited) [ 2024 (3) TMI 41 - SUPREME COURT ] held that the assessees would not be under a legal obligation to deduct tax at source on the income/profit component in the payments received by the distributors/franchisees from the third parties/customers, or while sel .....

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..... . For the Respondent(s): Mr. Rohit Sud, Advocate and Mr. Sachin Jolly, Advocate (through video conferencing). SANJEEV PRAKASH SHARMA, J.(ORAL) 1. By way of this common order, both the aforesaid appeals are being decided. 2. Appellant(s)/Revenue have filed the appeals against the order passed by the Income Tax Appellate Tribunal, Delhi (for short the ITAT ), whereby it was held that the discount of .....

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..... sessees would not be under a legal obligation to deduct tax at source on the income/profit component in the payments received by the distributors/franchisees from the third parties/customers, or while selling/transferring the pre-paid coupons or starter-kits to the distributors. Section 194H of the Act is not applicable to the facts and circumstances of this case. Accordingly, the appeals filed by .....

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