Principal-to-principal dealer incentives and TDS under section 194H raised no substantial question of law.

Dealer incentive paid on sales made on a principal-to-principal basis was examined for TDS liability under section 194H of the Income-tax Act. The Delhi HC noted that the same relationship between the assessee and its dealers had already been held to be principal-to-principal for the immediately preceding year, that the Revenue had accepted that earlier view, and that subsequent authority had also gone against the Revenue. On that basis, the court found no warrant to reopen the issue as a substantial question of law and did not entertain the question.

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Issues: Whether dealer incentive paid on sales made on principal-to-principal basis was liable for deduction of tax at source under section 194H of the Income-tax Act, 1961.

Analysis: The impugned order followed the Tribunal's earlier view for the immediately preceding assessment year, where the relationship between the assessee and its dealers had been examined and held to be principal-to-principal. That earlier decision had been accepted by the Revenue, and the same issue had also been held against the Revenue in subsequent authority. On that basis, no warrant was shown to reopen the question as a substantial issue of law.

Conclusion: The question did not give rise to any substantial question of law and was not entertained.

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