https://www.taxtmi.com/caselaws?id=12446 Discount allowed to licensed stamp vendors under the Gujarat Stamps Supply and Sales Rules, 1987 was held to be a purchase discount on a principal-to-principal basis, not commission or brokerage. The court found that the vendors bought stamp papers from the Government at a reduced price, title passed on purchase, and regulatory controls did not by themselves create an agency relationship. Section 194H applies only where payment is made to a person acting on behalf of another, so the essential element of agency was absent. The communications directing tax deduction at source were therefore unsustainable. en-us Fri, 28 Jun 2002 00:00:00 +0530 Tue, 30 Sep 2025 17:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12446 Discount allowed to licensed stamp vendors under the Gujarat Stamps Supply and Sales Rules, 1987 was held to be a purchase discount on a principal-to-principal basis, not commission or brokerage. The court found that the vendors bought stamp papers from the Government at a reduced price, title passed on purchase, and regulatory controls did not by themselves create an agency relationship. Section 194H applies only where payment is made to a person acting on behalf of another, so the essential element of agency was absent. The communications directing tax deduction at source were therefore unsustainable. Case-Laws Income Tax Fri, 28 Jun 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12446