There was a different view of High Courts on the issue of deduction of tax at source on AIR line paying the supplementary commission to agent on the selling of tickets.     On appeal the court held that the assessees were required to deduct tax at source under section 194H of the Act on the supplementary commission accrued to travel agents entrusted by the assessees to sell airline tickets  an agent acting of its own account does not, in principle, alter the nature of a contract of agency and only gives rise to the consequences mentioned under sections 215 and 216 of the Contract Act if the conditions contained within them exist. In any case, given that information regarding the supplementary commission was available to the airlines, the airlines could not have absolved themselves of liabilities under the Act attached to the accrual of that additional portion of income to the agent. These amounts were incidental to the transaction by which the flight tickets were sold on behalf of the air carriers and was for their benefit. Liable to deduct tax at source.  If recipient includes amount in its income and pays taxes  the  assessee cannot be held in default.  Interest leviable for period between date of  default in deduction and date on which the recipient paid tax.  Different views High Courts  is a reasonable cause  hence the  Levy of penalty was  quashed. (AY.2001-02)