TDS u/s 194 R Applicability

This discussion examines the TDS u/s 194R liability for wholesale distributors receiving payouts from an MNC. The core question is whether distributors must deduct TDS again when passing these benefits to sub-distributors. While initially suggested that distributors are merely distributing benefits, the feasibility of collecting sub-distributor PANs for direct TDS deduction is a challenge. If collecting PANs isn't possible, distributors may indeed be liable for TDS deduction, provided the transaction values exceed the threshold.