TDS Not Applicable on Discounts for Prepaid Services; No Disallowance u/s 40(ia) as Transaction Was Principal-to-Principal.

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....TDS u/s 194H - disallowance u/s 40(ia) - discount to the distributors for starter packs and recharge coupons for its prepaid services - apart from CIT(A)’s order setting aside the order passed u/s 201 was not carried in appeal tribunal independently find that transaction was on principal to principal basis, TDS u/s 194H, would not be made since the payment was not for commission or brokerage - no disallowance is called for....