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In favour of assessee.The assessee is not required to deduct tax under section 194H of the Act on the prepaid SIM Cards and hence, the assessee is not in default as per provisions of section 201(1) of the Act.

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Sec. 194H of Income Tax Act, 1961— TDS — The assessee is not required to deduct tax under section 194H of the Act on the prepaid SIM Cards and hence, the assessee is not in default as per provisions of section 201(1) of the Act. Once, the assessee is treated as assessee not in default u/s.201(1), the interest u/s.201(1A) is not required to be charged.—VODAFONE IDEA LIMITED vs. Asstt. CIT.[2020] 26 ITCD Online 013 (ITAT-CUTTACK)