https://www.taxtmi.com/caselaws?id=785117 Whether payments/discounts to distributors for sale of prepaid products attract TDS under s.194H - Court applied the Supreme Court's restrictive construction of "agent" (agent = person able to affect principal's legal position by contracting or disposition) and examined the indicia of agency. Reasoning: distributors/franchisees merely received right-to-use airtime and did not possess contractual/dispositive authority to bind the principal; relationship akin to independent contractors not falling within Explanation (i) to s.194H. Outcome: s.194H does not apply; respondent had no statutory obligation to deduct tax at source on those payments. en-us Wed, 26 Nov 2025 00:00:00 +0530 Thu, 15 Jan 2026 14:21:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785117 Whether payments/discounts to distributors for sale of prepaid products attract TDS under s.194H - Court applied the Supreme Court's restrictive construction of "agent" (agent = person able to affect principal's legal position by contracting or disposition) and examined the indicia of agency. Reasoning: distributors/franchisees merely received right-to-use airtime and did not possess contractual/dispositive authority to bind the principal; relationship akin to independent contractors not falling within Explanation (i) to s.194H. Outcome: s.194H does not apply; respondent had no statutory obligation to deduct tax at source on those payments. Case-Laws Income Tax Wed, 26 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785117