DCIT (OSD)(TDS)-2(3), MUMBAI vs. TOTAL ENERGIES MARKETING INDIA PVT LTD, MUMBAI

Appeals are partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm

pricing and to counter various market challenges. Commission/discount offered by the assessee is directly linked or related to its liquidity which proves that these are not normal discount offered by the assessee but represents the amount of commission. Accordingly he held that the amount of discount offered is commission in substances and provision of section 194H applies, therefore assessee should