TDS not deductible on Trade Offers Provided to Distributors

Nokia India Pvt. Ltd Vs ACIT (ITAT Delhi) It was noted by the AO that assessee had offered trade incentives to the distributors amounting to Rs.191,75,43,450/-which included Rs.130,38,78,222/- offered to HCL Infosystems Ltd. The assessee was asked to show-cause as to why the amounts not be disallowed u/s 40(a)(ia) on account of non-deduction tax at source. Assessee made the detailed submissions inter alia contending that the provision of section 194H, 194C, 194J were not applicable to the case because the payment was not for any contractor of services or work, there was no relationship of agen...