SHRI AMIT KUMAR SHIVHARE,KOREA vs. INCOME TAX OFFICER 2(3), BILASPUR
In the result, appeal of the assessee is allowed in terms of our aforesaid observations
ITA 198/RPR/2017[2008-09]Status: DisposedITAT Raipur09 May 2022AY 2008-09
Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकरअपीलसं. / Ita No. 198/Rpr/2017 "नधा"रणवष" / Assessment Year : 2008-09 Shri Amit Kumar Shivhare, Prop. M/S. Amit Infotech, Main Chowk, Baikunthpur, P.O. Baikunthpur, Dist. Korea (C.G.) Pan : Bdzps8815C .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer-2(3), Bilaspur (C.G.) ……""यथ" / Respondent Assessee By :Shri G.S. Agrawal, Ar Revenue By :Shri G. N Singh, Dr
For Appellant: Shri G.S. Agrawal, ARFor Respondent: Shri G. N Singh, DR
Section 143(3)Section 194HSection 40
section 194H would not be applicable to discounts extended to pre-paid SIM distributors on transfer of pre-paid SIM cards/talk time.
7. In the backdrop of our aforesaid observations, we concur with the claim of the Ld. AR that now when the assesee was not obligated to deduct any tax at source qua the retailer discounts which were received