The appeals in this case arise from differing High Court judgments regarding the applicability of Section 194-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 194-H did not apply. The Supreme Court's common judgment aims to resolve this inconsistency, interpreting Section 194-H and determining whether the payments in question constitute commissions.