THE COMMISSIONER OF INCOME TAX vs. KARNATAKA POWER TRANSMISSION CORPORATION LTD

a a $1 I L r *oji ci & ci 10) H!NH flVIVNNVN JO INflOD HDIH V>fllVNlrn JO IJDO) HOiii V.VVc’NJv)I JO LNflO) H9!H VJVIVNNfl JO JDIflOD H9H VJIVJVNNn 4fl I Nfl

a C, praying that thh Hon’ble Court may be psed to formulate the substantial questhns of law stated Unhi ; i ifA coming on for Hearing this day, an*a J, delirM tbe hltng appeal is by the rnue The substantial questiorN of law that arise for consideration in this appeal are as u&er: (1$Thether the lflbunal was gM in splitting up the cznfract which, aasrdihg to the revenue, was one MB of the composite ain&, into p a as part of the contract attributable to the vabe ofthe maals irwolved in the execution ofthe work and otherpart of the contract such as dull works and taking the view that tax was required to be deducted at smn only in respect of the work pert of the contract and not materialpert ofthe contract? (2)Whether the Tribunal wasftastifled in concluding that interest under Salon 201(M) of the Income Tax Act, lxi is,

3 not lwik the assessee was not liable W maa dedwtions In rsspect of the value of the material pwt of the esnb’act, though the contract was one of whole cnntracO’ fl Court Id an occasion to consa’ aph w&re the said quattns were the case of The fkanandnksar 1Ha Th* andn va Xantatakm suer flnnsadnton Vorporutton I4mkttd disposed of on at date and has answered the said subtantiel questions of law in btir of the assasee and agaSt the reinue. 3 refore, following the aforesaid judgment, this appeal is aho dismise& JUDGE Sd/s JUDGE db&