Dismissing the appeal of the assesse , the Tribunal held that ; Recharge vouchers supplied to distributors at discount was held to be commission ,considering the principal and agent relation hence liable to deduct tax at source . Tribunal also held that the distributor is merely a link between assessee and ultimate consumer/subscriber and distributor can at best enforce obligation on the part of assessee to provide connection/talk-time to subscriber which itself would not change the characteristic of transaction from ‘principal to agent’ to ‘principal to principal’. Therefore the order passed by Assessing Officer, as confirmed by Commissioner (Appeals), by holding that assessee is a defaulter under S. 201(1) and consequently liable to pay interest under S. 201(1A), is in accordance with law. ( AY. 2010-11 to 2015 -2016 )