Assessee providing post-paid and pre-paid telecommunication services through various channel partners (distributors) under agreements entered into between them.  Assessee sold its products, i.e., starter kits and pre-paid vouchers, to distributors in bulk against advance payments. As per the assessee, starter kits and recharge coupon vouchers were sold to its various distributors on principal-to-principal basis at a discounted price than MRP with agreed rider that no product would be sold at a price more than MRP. The AO took a view that discount, i.e., difference between MRP and selling price, to distributors amounted to payment of commission which was liable to TDS u/s. 194H. Tribunal  held that, it was not a sale of goods but a case of providing telephone services and, hence, there could be no sale of goods from service provider i.e. assessee to its distributors so as to create a principal-to-principal relationship. Discount on pre-paid products offered by assessee was in nature of ‘commission’ which did attract S. 194H of the Act . (AY 2007- 08 to 2011 – 12)