IT: Sale of SIM card involves sale of right to services. Therefore, the relationship between the assessee and the distributor would be that of principal and principal and not principal and agent. Moroever, where SIM card is sold at discounted price, there is no payment of commission or brokerage to distributor. Hence, TDS u/s 194H is not applicable on sale of SIM cards and prepaid recharge coupons by Telecom Company to distributors at discounted MRP.
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