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The Court held that the assessee was not liable to deduct tax at source u/s 194H on the discounted price paid to franchisees/distributors, as they were not agents or commission recipients. The Supreme Court's decision in Bharti Airtel Limited's case, involving similar facts, was applied, wherein it was ruled that Section 194H was not attracted. Consequently, further adjudication was deemed unnecessary, and the question was answered in favor of the assessee against the revenue.
The Court held that the assessee was not liable to deduct tax at source u/s 194H on the discounted price paid to franchisees/distributors, as they were not agents or commission recipients. The Supreme Court's decision in Bharti Airtel Limited's case, involving similar facts, was applied, wherein it was ruled that Section 194H was not attracted. Consequently, further adjudication was deemed unnecessary, and the question was answered in favor of the assessee against the revenue.
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