Section 194H doesn’t apply on sells of pre-paid SIM at discounted price to distributors

ACIT Vs Bharti Haxacom Ltd (ITAT Delhi) ITAT Delhi held that provisions of section 194H of the Income Tax Act are not applicable on sells of pre-paid SIM at discounted price to the distributors. Further, as no TDS deductible, disallowance u/s 40(a)(ia) cannot be sustained. Facts- The assessee company is engaged in the business of Cellular phone and landline services and its associated value added services in the telecom circle of Rajasthan and North East pursuant to the licence granted by Department of A sum of Rs.394,76,33,759/- was debited in the P&L account towards payment of licence fe...