No penalty for non deduction of TDS on sale of SIM Cards/recharge coupons at discounted rate

Tribunal held that sale of SIM Cards/recharge coupons at discounted rate to distributors is not commission and therefore, not liable to TDS provisions u/s. 194H of the Act. Once, the substratum for levy of penalty has eroded there is no question for sustaining the penalty.

The penalty u/s. 271C has been levied in respect of violation of provisions of section 194H o

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