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22nd December, 2022 holding petitioners liable to pay TDS. According to the petitioners who acts as a broker in teas auction are not liable to pay tax on tea sample drawn specifically for tea tasting and valuation, as ultra vires and unconstitutional in view of provision of Section 194R of the Income Tax Act, 1961 by contending that it is not they are not real beneficial and owner of the goods and they merely distributes sample of tea to the buyers on behalf of the sellers and as such those free sample cannot be treated as perquisite in the hands of the petitioners/broker as an income.