Section 194R Applicability for Silver Coins to Dealers

The Company has a Distributor in Ahmedabad. Distributor has more than 200 Dealers. The Company sells to Distributors and Distributors in turn sells to Dealers. The Company in consultation with Distributor designed a Silver Coin Scheme for Dealers. The Silver coins are purchased by Company in its books and thereafter distributed to all the Dealers, who have achieved the Target under the Scheme. In this case, 1) Please confirm whether Section 194R is attracted or not?  2) What should be TDS obligation of Company?  3) From whom the Company should deduct TDS either from Distributor or Dealer? 4) Company does not have direct dealings with Dealer in that case, what it should do for TDS Obligation and Deducting from whom? 5) Which is the Key Reason for Attracting TDS Liability on the Company?