Held that, the Assessee Company sold its products to distributors at a price lower than the MRP. This difference has been opined by the PCIT as a commission requiring deduction of tax at source under s.194H of the Act. The said difference by no stretch of imagination, can be considered as commission or brokerage paid by the assessee to its stockists. In order to attract s. 194H of the Act, it is apparent that principal and agent relation must be established. The assessee sold its products to stockists on principal-to-principal basis. Thus, the relation between the assessee and its stockists cannot be described as that of principal and agent. Therefore, the PCIT was not justified in holding the assessment order to be erroneous and prejudicial to the interest of the Revenue on account non-deduction of tax at source from such amount warranting any disallowance under s. 40(a)(ia) of the Act. Other issues the Revision was up held. (AY. 2012-13)