No section 194H TDS on discounts on transfer of pre-paid SIM cards/talk time

Amit Kumar Shivhare Vs ITO (ITAT Raipur) ITAT held that tax withholding provisions under section 194H would not be applicable to discounts extended to pre-paid SIM distributors on transfer of pre-paid SIM cards/talk time.  On a perusal of the invoices which were issued by M/s. Idea Cellular Ltd. to the assessee, a distributor of Idea recharge coupons, we find that the assessee was in receipt of two facet discounts on the recharge coupons from M/s. Idea Cellular Ltd., viz. (i) discount to distributor @1.47% on the MRP; and (ii) discount to retailers @3% on the MRP. The aforesaid discounts were...