In one case, the Supreme Court ruled that where the assessee-airlines had passenger sales agency (PSA) agreements with travel agents under which they would pay commission to them on the published fare of tickets sold by them on behalf of airlines, supplementary commission—additional amounts above and beyond the net fare collected from customers—were incidental to the transaction by which flight tickets were sold on behalf of air carriers, and the assesse was liable to deduct TDS under section 194H on same.
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