VODAFONE CELLULAR LIMITED,COIMBATORE vs. DCIT, COIMBATORE

In the result, all the appeal filed by the assessee are partly allowed for statistical purposes

Bench: Shri A. Mohan Alankamony & Shri Duvvuru Rl Reddy

price at which these are transferred to the prepaid distributors. Since no payment is made by the assessee to its prepaid distributors, the discount extended to the prepaid distributors is in the nature of trade margin and such discount cannot be termed as commission so as to attract the provisions of section 194H