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2017 (10) TMI 1527 - ITAT JAIPURTDS u/s 194H - commission paid to various distributors - relation between assessee and distributors - HELD THAT:- As decided in own case [2015 (6) TMI 443 - ITAT JAIPUR] Assessee has issued sale invoices of SIM cards to its distributors net of discount. Similarly relevant entries have been entered in the books net of discount. Discount or so called commission has not been separately paid to distributors, thus there is no payment of any income - What has been effected by way of these sale transactions is sale of service embedded or encrypted on SIM cards, and treating same as ‘Principal to Principal transaction’. Circumstances, rival submission and material available on record assessee is not liable for deduction u/s 194H. Therefore we reverse the orders of lower authorities on these issues and delete the demand. - Decided in favour of assessee.
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