Payments to banks for processing of credit card transactions is not liable for deduction of tax at source u/s. 194H of the Act as in such transactions, the banks do not act as the ‘agents’ of the customer and therefore the payments cannot be characterised as commission. The banks enter into such transactions as independent parties. The fee charged/retained by them is towards provision of banking services, and not brokerage or commission.  Appeal of revenue is dismissed .Followed CIT  v. JDS Apparels   P. Ltd ( 2015) 370 ITR 454 (Bom) (HC),CIT (TDS) v .Larsen and Toubro Ltd ,  ITA No . 769 of 2016 dt 4-12- 2018  (Bom) (HC)  )