AO treated the Respondent Company as assessee in default and orders were passed under section 201/201(1A) of the Act. Moreover, the Revenue contends that the Respondent company has imposed various restrictions on stockists/distributors/ wholesalers while selling the products. Only Respondent company decides the area in which stockist has to sell, it monitors and controls the stocks and hence the relationship between Respondent company and stockist is that of Principal to Agent. As the Respondent company did not deduct TDS, the Respondent company was treated as “appellant” in default. AR of the Respondent company argued the case at length and also submitted a note in which it was stated that the Respondent company sends the goods to Clearing and Forwarding Agent (CFA) selected by company.