Tribunal held that the discount extended to the prepaid distributors was in the nature of margin for such distribution of the right to prepaid services and such discount did not qualify as commission within the meaning of section 194H . Thus, the assessee was not required to deduct tax under section 194H on the prepaid SIM cards and hence, the assessee was not in default in terms of the provisions of section 201(1) . With regard to the provisions of section 194J in respect of roaming charges, the assessee was not required to deduct tax under section 194J and consequently the assessee was not to be treated as an assessee in default under section 201(1) . The roaming charges were not paid for rendering any managerial, technical or consultancy services and hence, did not fall under the category of fee for technical services. Therefore, the assessee was not required to deduct tax on such roaming charges under section 194J . Once the assessee was treated as not in default under section 201(1) , interest under section 201(1A) was not required to be charged.( AY.2009-10 to 2012-13)