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    <title>2015 (6) TMI 448 - ITAT JAIPUR</title>
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    <description>Margin allowed to prepaid distributors on sale of SIM cards, recharge coupons and related prepaid products was treated as a trade discount arising from a principal-to-principal sale, not as commission. The invoices were issued net of discount and no separate commission was credited or paid, so the arrangement lacked the principal-agent relationship required for section 194H. On those facts, the embedded discount did not attract tax deduction at source, and the TDS demand on the disputed margins was deleted.</description>
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      <description>Margin allowed to prepaid distributors on sale of SIM cards, recharge coupons and related prepaid products was treated as a trade discount arising from a principal-to-principal sale, not as commission. The invoices were issued net of discount and no separate commission was credited or paid, so the arrangement lacked the principal-agent relationship required for section 194H. On those facts, the embedded discount did not attract tax deduction at source, and the TDS demand on the disputed margins was deleted.</description>
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