2024 (11) TMI 507

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....he Appellant(s)/Income Tax Department : Mr. Amanpreet (A.P.) Singh, Senior Standing Counsel,. For the Respondent(s): Mr. Rohit Sud, Advocate and Mr. Sachin Jolly, Advocate (through video conferencing). SANJEEV PRAKASH SHARMA, J.(ORAL) 1. By way of this common order, both the aforesaid appeals are being decided. 2. Appellant(s)/Revenue have filed the appeals against the order passed by the I....

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....Cellular Limited (supra), reads as under: "42. In view of the aforesaid discussion, we hold that the assessees would not be under a legal obligation to deduct tax at source on the income/profit component in the payments received by the distributors/franchisees from the third parties/customers, or while selling/transferring the pre-paid coupons or starter-kits to the distributors. Section 194H of....