https://www.taxtmi.com/highlights?id=96121 Whether payments to distributors for pre-paid products attracted TDS under Section 194H - applying the Supreme Court's restricted construction of "agent" (limited to persons able to affect the principal's legal position by contract or disposition of property and assessed by the indicia in para 8), the relationship was not that of an agent within Explanation (i) to Section 194H; reasoning distinguishing principal-agent from master-servant and emphasizing contract/disposition indicia. Consequence: no legal obligation to deduct TDS on the discount/income element received by distributors; Section 194H held inapplicable - decision for the assessee. - ITAT en-us Sat, 17 Jan 2026 11:54:32 +0530 Sat, 17 Jan 2026 11:54:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96121 Whether payments to distributors for pre-paid products attracted TDS under Section 194H - applying the Supreme Court's restricted construction of "agent" (limited to persons able to affect the principal's legal position by contract or disposition of property and assessed by the indicia in para 8), the relationship was not that of an agent within Explanation (i) to Section 194H; reasoning distinguishing principal-agent from master-servant and emphasizing contract/disposition indicia. Consequence: no legal obligation to deduct TDS on the discount/income element received by distributors; Section 194H held inapplicable - decision for the assessee. - ITAT Highlights Income Tax Sat, 17 Jan 2026 11:54:32 +0530 https://www.taxtmi.com/highlights?id=96121