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 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.

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 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 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 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 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 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 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.

For AY 2010-11 and 2011-12, the Tribunal directed the AO to restrict the disallowance under Section 14A based on investments yielding exempt income, following a Special Bench order. For AY 2013-14, since there was no exempt income, the disallowance under Section 14A was deleted, following Delhi High Court precedent.

The Tribunal held that the assessee's claim based on AS-9 is not sustainable as it follows the mercantile system of accounting under Section 145 of the Income Tax Act. Income accrues under the mercantile system even if bills are not raised.

For AY 2010-11 and 2011-12, the Tribunal directed the AO to restrict the Section 14A disallowance based on investments yielding exempt income, following a Special Bench order. For AY 2013-14, where no exempt income was earned, the disallowance under Section 14A was deleted, following Delhi High Court precedent.

For AY 2010-11 and 2011-12, the Tribunal directed the AO to restrict the disallowance under Section 14A based on investments yielding exempt income, following a Special Bench order. For AY 2013-14, since there was no exempt income, the disallowance under Section 14A was deleted, following Delhi High Court precedent.