TDS on IUC charges paid to foreign / non-resident telecom operators and discount to prepaid distributors

Addition on account of discount extended to prepaid distributors Third proviso to section 194H will get attracted only when the nature of payment is “commission or brokerage”. Parties before us agree that majorly the distribution of products by BSNL and MTNL takes place through Public Call Office franchisees since this was an infrastructure existing with them even before mobile telephone services became popular. Moreover, as upheld by Hon’ble Punjab & Haryana High Court in case of appellant itself (supra) that “…….. the above extracts from the Board circular would show...