https://www.taxtmi.com/caselaws?id=254299 Whether deduction of tax at source applies to discounts/commissions on sale of prepaid SIM cards hinges on the character of the transaction as sale of goods or a service relationship. The court found that where the assessee accounts sales at gross and separately records commission/discount as payment to distributors, the arrangement operates as a service/commission and s.194H is attracted; conversely, where sales are recorded net and the discount is not reflected in books, no income accrues to the distributor and s.194H does not apply. Consequently the matter was remitted to verify accounting treatment; decision favoured the assessee where discounts were unrecorded. en-us Thu, 14 Aug 2014 00:00:00 +0530 Thu, 05 Feb 2026 16:19:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=254299 Whether deduction of tax at source applies to discounts/commissions on sale of prepaid SIM cards hinges on the character of the transaction as sale of goods or a service relationship. The court found that where the assessee accounts sales at gross and separately records commission/discount as payment to distributors, the arrangement operates as a service/commission and s.194H is attracted; conversely, where sales are recorded net and the discount is not reflected in books, no income accrues to the distributor and s.194H does not apply. Consequently the matter was remitted to verify accounting treatment; decision favoured the assessee where discounts were unrecorded. Case-Laws Income Tax Thu, 14 Aug 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=254299