https://www.taxtmi.com/caselaws?id=465568 Discounts/incentives allowed to distributors on sale of products raised the issue whether tax was deductible u/s 194H. Relying on the distribution agreement and prior co-ordinate bench ruling, the Tribunal held the distributor purchased and resold in its own right, with risks and rewards of ownership passing on delivery; the relationship was principal-to-principal and the discount was a price reduction, not commission/brokerage. Consequently, no TDS was required u/s 194H and the payer could not be treated as an assessee-in-default. Provision/payment for delayed payments to micro and small enterprises raised the issue whether TDS was deductible u/s 194A. Following its earlier order, the Tribunal held the amount had an immediate nexus with trade liability and formed part of purchase consideration, not "interest" u/s 2(28A); hence, no liability u/s 201(1)/201(1A) arose and the revenue appeal was dismissed. en-us Fri, 30 Dec 2022 00:00:00 +0530 Mon, 29 Dec 2025 10:57:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465568 Discounts/incentives allowed to distributors on sale of products raised the issue whether tax was deductible u/s 194H. Relying on the distribution agreement and prior co-ordinate bench ruling, the Tribunal held the distributor purchased and resold in its own right, with risks and rewards of ownership passing on delivery; the relationship was principal-to-principal and the discount was a price reduction, not commission/brokerage. Consequently, no TDS was required u/s 194H and the payer could not be treated as an assessee-in-default. Provision/payment for delayed payments to micro and small enterprises raised the issue whether TDS was deductible u/s 194A. Following its earlier order, the Tribunal held the amount had an immediate nexus with trade liability and formed part of purchase consideration, not "interest" u/s 2(28A); hence, no liability u/s 201(1)/201(1A) arose and the revenue appeal was dismissed. Case-Laws Income Tax Fri, 30 Dec 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465568