ITAT Bangalore Judgments — February 2019

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal granted permission to the assessee to withdraw the appeal. The appeal was dismissed as withdrawn because it had become infructuous.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal agreed that the advance lease rent should be taxed over 30 years, but disagreed with the CIT(A)'s method of calculation. The Tribunal determined a more precise method for calculating the taxable amount each year, considering the actual rent receivable and the discounted value of the balance.

The Tribunal held that the relationship between the assessee and its distributors was principal-to-principal, not principal-to-agent. This was based on the distributors' ability to sell prepaid SIM cards and recharge vouchers at prices below the MRP, and the fact that the distributorship agreement's clauses did not alter this fundamental relationship.

The Tribunal held that there was no understatement of gross receipts for the drama company and deleted the additions sustained by the CIT(A). Regarding the Kalyana Mantapa, the Tribunal found that the assessee neither received income nor incurred expenditure, thus deleting the additions sustained by the CIT(A).

The Tribunal set aside the CIT(A)'s order and restored the matter back to the CIT(A)'s file for a fresh decision. This was done in the interest of justice to provide the assessee with one more opportunity to be heard.

The Tribunal held that only those investments that yielded exempt income during the relevant assessment years should be considered for computing the average value of investments for the purpose of disallowance under Section 14A read with Rule 8D(2)(iii). The matter was restored to the AO for recomputation.

The Tribunal held that the date of issue of a notice under Section 148 is the date it is handed over to postal authorities for service, not the date it bears. Reassessment proceedings initiated by notices issued beyond the six-year limitation period were deemed invalid.

The Tribunal held that the interest claimed was not payable on an accrual basis as the assessee was unable to discharge its obligations under the agreement. The liability was considered a contingent liability or no liability in the eyes of law.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that there was no understatement of gross receipts for the drama company and deleted the additions sustained by the CIT(A). Regarding the Kalyana Mantapa, the Tribunal found that the assessee neither received income nor incurred expenditure, thus deleting the additions sustained by the CIT(A).

The Tribunal held that there was no understatement of gross receipts for the drama company and deleted the additions sustained by the CIT(A). Regarding the Kalyana Mantapa, the Tribunal found that the assessee neither received income nor incurred expenditure, thus deleting the additions sustained by the CIT(A).

The Tribunal held that there was no understatement of gross receipts for the drama company and deleted the additions sustained by the CIT(A). Regarding the Kalyana Mantapa, the Tribunal found that the assessee neither received income nor incurred expenditure, thus deleting the additions sustained by the CIT(A).

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.

The Tribunal held that KPTCL had discharged its obligation under Section 192 of the Act by forming a bonafide belief that its employees were to be regarded as State Government employees. Therefore, proceedings under Section 201(1) and 201(1A) were quashed.