https://www.taxtmi.com/caselaws?id=311914 ITAT Mumbai ruled in favor of the assessee on two TDS issues. First, regarding section 194H, the tribunal held that sale of prepaid sim cards/recharge vouchers to distributors at discounted prices cannot be treated as commission/discount requiring TDS deduction, as distributors earn income only upon resale and the actual income amount cannot be predetermined. Second, for section 194J, roaming charges paid to other telecom operators do not constitute fees for technical services requiring TDS deduction, following precedent from ITAT Chandigarh. Consequently, no disallowance under section 40(a)(ia) was warranted. en-us Fri, 24 Feb 2023 00:00:00 +0530 Sat, 20 Jan 2024 21:00:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311914 ITAT Mumbai ruled in favor of the assessee on two TDS issues. First, regarding section 194H, the tribunal held that sale of prepaid sim cards/recharge vouchers to distributors at discounted prices cannot be treated as commission/discount requiring TDS deduction, as distributors earn income only upon resale and the actual income amount cannot be predetermined. Second, for section 194J, roaming charges paid to other telecom operators do not constitute fees for technical services requiring TDS deduction, following precedent from ITAT Chandigarh. Consequently, no disallowance under section 40(a)(ia) was warranted. Case-Laws Income Tax Fri, 24 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311914