TMI Blog2020 (1) TMI 701X X X X Extracts X X X X X X X X Extracts X X X X ..... cipal relationship and not that of principal to agent. The Tribunal followed the decision of the Karnataka High Court in the case of Bharati Airtel Ltd. vs. DCIT [ 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 to deduct the TDS under Section 194H. When the transac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 3. This Appeal pertains to the Assessment Year is 2010-11. 4. The Appellant-Revenue has raised the following questions as a 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nal noted that there was no decision of this Court on this issue on that date. 6. Learned counsel for the parties have tendered the copy of the order 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 B ..... X X X X Extracts X X X X X X X X Extracts X X X X
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