BHARTI CELLULAR LIMITED (NOW BHARTI AIRTEL LIMITED)versusASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE 57, KOLKATA AND ANOTHER
Case No.: CIVIL APPEAL No. 7257/2011
Decision Date: 28-02-2024
Disposal: Disposed off
Neutral Citation: 2024INSC148

SANJIV KHANNA*, SARASA VENKATANARAYANA BHATTI Issue for Consideration The liability to deduct tax at source u/s.194-H, Income Tax Act, 1961 on the amount which, as per the Revenue, is a commission payable to an agent by the assessees-cellular mobile telephone franchise/distributorship agreement between the assessees and the franchisees/distributors. Headnotes Income Tax Act, 1961 – s.194-H – When not attracted – Assessees entered into franchise or distribution agreements and sold start-up kits, recharge vouchers at a discounted 

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