Karnataka High Court Judgments — 2011

The tribunal held that the agreements conferred only a license to access the passive infrastructure and use it for specific purposes, not a transfer of right to use the infrastructure. Therefore, it did not constitute a deemed sale.

The High Court held that interest income earned from fixed deposits is to be construed as income of the business of the undertaking, establishing a direct nexus with the business income. Therefore, it is eligible for exemption under Section 10B.