Section 194H – Whether difference between commercial price and published price can be classified as commission or not?

CIT Vs. Qatar Airways (332 ITR 253) (Bombay HC)  –In an appeal preferred by the Revenue, the following question was raised:

Whether on the facts and in the circumstances of the case and in law, the difference in amount between commercial price and published price is special commission in the nature of commission or brokerage within the meaning of Explanation (i) to section 194H of the Income-tax Act, 1961?

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