Discount granted by Tata Sky to distributor couldn't be considered as commission under sec. 194H TDS

Where assessee, engaged in business of providing DTH services, sold set top Box (STB) and recharge coupon vouchers to distributors at a discounted rate, discount so offered could not be considered as commission and, hence, not liable for deduction of tax at source under provisions of section 194H

Installation of dish antenna and incidental hardware by installation service providers (ISPs) amounted to work contract under section 194C and no technical expertise was required so as to make assessee liable under provisions of section 194J

Document management services was not a technical or professional work which required special skills, thus, provision to section 194J could not be applied

Refer:[2018] 99 taxmann.com 272 (Mumbai - Trib.)