Difference in MRP & Sales price is not Commission to attract section 194H TDS

Wockhardt Limited Vs PCIT (ITAT Pune) it is seen that the assessee company sold its products to distributors at a price lower than the Maximum Retail Price (MRP), which difference has been opined by the ld. PCIT as Commission requiring deduction of tax at source u/s 194H of the Act. It is simple and plain that a manufacturer would sell his goods to Stockists or Distributors at a price below the MRP, who, in turn, will add up their margin and then sell the products to the retailers. The MRP is the price which is charged by a Retailer from the ultimate consumers. All the intermediaries between t...