In Brief
Prasar Bharati (Doordarshan) paid commission to advertising agencies for telecasting advertisements under a written agreement. The Income Tax Department contended that these payments attracted tax deduction obligations under Section 194H of the Income Tax Act, 1961. Prasar Bharati argued the payments were not 'commission' but principal-to-principal transactions. The Supreme Court upheld the Department's position, holding that the agreement expressly termed the payments as 'commission', establishing a principal-agent relationship, and thus Section 194H deduction obligations applied. The Court dismissed Prasar Bharati's appeals, confirming it was obligated to deduct tax at source from agency payments.",
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