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    <title>2020 (6) TMI 174 - ITAT CUTTACK</title>
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    <description>Prepaid-distributor discounts were treated as a principal-to-principal sale margin on the right to service, not commission or brokerage, so no income was paid or accrued to the distributors and section 194H was held inapplicable, with no default under section 201(1). Roaming charges paid to other telecom operators were treated as consideration for automated facilities without human intervention, not managerial, technical or consultancy services, so section 194J did not apply and no interest under section 201(1A) survived. The resulting TDS additions and related interest demands were deleted.</description>
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