Held, dismissing the appeals the Court held that the payments from the distributor to the assessee had no link with the further sales made by the distributor. The decision to sell the products at a price less than the invoice price was taken after the products had reached the distributor and after the invoices were raised by the assessee. The distributor was liable for making payment of full invoice value. The Commissioner (Appeals) had recorded that reduction in price by the distributor was to overcome unfavourable market changes and special occasions on which discount was given to the purchasers of computers and peripherals. He had rightly recorded that the distributors were required to place the purchase order under the agreement and the assessee reserved the right to accept or reject any order. The inventory risk after acquiring the product was that of the distributor. The facts recorded by the Commissioner (Appeals) that payment from the distributor to the assessee had no link with the further sale made by the distributor had been confirmed by the Tribunal as the last fact finding authority. The Tribunal was right in confirming the order of the Commissioner (Appeals) cancelling the order passed under section 201(1) and (1A). (AY. 2012-13, 2015-16)