Assessee was a manufacturer of computers and peripherals. It supplied its product to distributors.  Assessing Officer held that as assessee had paid money to distributors therefore, it amounted to commission liable to TDS.  On appeal, Commissioner (Appeals) held that  in order to ensure that sale of product was not adversely affected by unfavourable market changes, assessee had suggested distributors to sell products at price less than actual price mentioned in invoices raised by assessee.  Further, such contingencies arose on several occasions due to festival discounts, sudden change in market value, introduction of similar products etc. and distributors sold product at their risk to dealers.  High Court by impugned order held that in view of factual findings recorded by Commissioner (Appeals) that payment from distributor to assessee had no link with further sale made by distributor, hence affirmed the order. High Court  affirmed the  order of the Tribunal. SLP of Revenue is dismissed. Followed CIT (TDS) v. Acer India (P.) Ltd. [2024] 298 Taxman 748/463 ITR 676 (SC).  (AY. 2012-13,  2015-16)