IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX , INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE
In the result, all the appeals of the assessees are allowed
ITA 497/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17
Bench: Shri Chandra Poojari & Smt. Beena Pillai
TDS, which acts as a defence against levy of penalty. IBM foreign entities had reasonable cause to not file a return under section 139