business of cellular mobile phone services and distribution of SIM cards
including prepaid and postpaid services. The prepaid services are in the
form of recharge ... cards. Only after the resale of those prepaid cards,
distributors would derive income. At the time of the assessee selling these
pre-paid cards
Company viz. mainly Starter Packs and Rechargeable coupons
viz. SIM Cards and Prepaid coupons. The assessee i.e. M/s Vodafone Essar
Cellular Limited dealing ... case of the Appellant, the activity involved is
selling of SIM cards and Prepaid Cards as per Invoice. There is no element of
either brokerage
assessee has not deducted the TDS on
discounts allowed for prepaid SIM Cards/ Talktime as distributor margin. After
considering the clarifications of the assessee ... DCIT in 372 ITR 33 has held that sale of SIM
cards/recharge coupons at discounted rate to distributors is not commission
and therefore
discount offered by the assessee to its distributors
for sale of SIM card is to be treated as "commission" as defined ... cellular services to customers and in the process where selling
prepaid SIM cards / recharge coupons in bulk to the Distributors by
offering discounts
business of cellular mobile phone services and
distribution of SIM cards including prepaid and postpaid services. The
prepaid services are in the form of recharge ... cards. Only after the resale of those prepaid cards, distributors would
derive income. At the time of the assessee selling these pre-paid cards
facts in brief are that the assessee company is
selling SIM cards and recharge coupons of Cellone of the
Chennai Telephones to various wholesale dealers ... onwards the assessee company has
distinguished the sale of SIM card and recharge coupons. In
respect of sale of recharge coupons the commission paid
business of distributor of M/s. Aircel Cellullar Services
Ltd. SIM cards & recharge coupons filed his return of income
for the assessment year ... recharge coupons such as documentation
for the sale of SIM and activation of the SIM cards. Hence the
"payments made by the assessee
Pudukkottai. The assessee
supplies to the various retail outlet shop prepaid SIM card / e-charge
of SIM cards. For the assessment year ... stated that
assessee is a wholesale dealer of Vodafone prepaid SIM cards and
recharge in e-mode in the district of Pudukkottai. It was submitted
assessee that the assessee is a wholesale dealer of SIM card and E-
Top-up of Bharathi Airtel Ltd. During the year, the assessee
admitted ... gross sale receipts on sale of SIM card and E-Topup at
Rs.13,62,38,329/- and as against the same claimed expenditure
assessee was a dealer in prepaid vouchers and SIM cards,
and has made cash deposit of Rs 1,33,80,000/- in the bank account ... submitted that assessee was a dealer in prepaid vouchers
and SIM cards and the Government had permitted the collection of
Specified Bank Notes (SBNs) towards
