The appeals in this case arise from differing High Court judgments regarding the applicability of Section -H of the Income Tax Act The Delhi and Calcutta High Courts ruled that ... payments by Bharti Airtel to franchisees distributors were commissions requiring tax deduction at source Conversely the Rajasthan Karnataka and Bombay High Courts held that these payments were not commissions and thus Section -H did not apply The Supreme Court's common judgment aims to resolve this inconsistency interpreting Section -H and determining whether the payments in question constitute commissions