IBM CORPORATION,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2) , BANGALORE

In the result, all the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS under section 192 in respect of all the salaries of the seconded employees, in respect of which costs were reimbursed to the IBM foreign companies; Thereafter, reassessment/ assessment proceedings were conducted on the IBM foreign entities and reassessment orders under section 143(3) read with section 147 of the Act/ assessment order under section

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS under section 192 in respect of all the salaries of the seconded employees, in respect of which costs were reimbursed to the IBM foreign companies; Thereafter, reassessment/ assessment proceedings were conducted on the IBM foreign entities and reassessment orders under section 143(3) read with section 147 of the Act/ assessment order under section

DCIT, BANGALORE vs. M/S BIOCON RESEARCH LTD.,, BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

1). Therefore this court is required to give meaning and effect to the said expression. It follows, therefore, that the obligation to deduct TAS arises only when there is a sum chargeable under the Act. Section 195(2) is not merely a provision to provide information to the Income tax Officer (TDS

BIOCON RESEARCH LIMITED,BANGALORE vs. CIT(A) I, BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

1). Therefore this court is required to give meaning and effect to the said expression. It follows, therefore, that the obligation to deduct TAS arises only when there is a sum chargeable under the Act. Section 195(2) is not merely a provision to provide information to the Income tax Officer (TDS

BIOCON RESEARCH LIMITED,BANGALORE vs. CIT(A) I, BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

1). Therefore this court is required to give meaning and effect to the said expression. It follows, therefore, that the obligation to deduct TAS arises only when there is a sum chargeable under the Act. Section 195(2) is not merely a provision to provide information to the Income tax Officer (TDS

DCIT, BANGALORE vs. M/S BIOCON RESEARCH LTD.,, BANGALORE

In the result, the appeal filed by the revenue is dismissed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

1). Therefore this court is required to give meaning and effect to the said expression. It follows, therefore, that the obligation to deduct TAS arises only when there is a sum chargeable under the Act. Section 195(2) is not merely a provision to provide information to the Income tax Officer (TDS

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS under section 192 in respect of all the salaries of the seconded employees, in respect of which costs were reimbursed to the IBM foreign companies; Thereafter, reassessment/ assessment proceedings were conducted on the IBM foreign entities and reassessment orders under section 143(3) read with section 147 of the Act/assessment order under section 143(3) of the Act were

IBM CANADA LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION, CIRCLE-1(2) , BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

TDS under section 192 in respect of all the salaries of the seconded employees, in respect of which costs were reimbursed to the IBM foreign companies; Thereafter, reassessment/ assessment proceedings were conducted on the IBM foreign entities and reassessment orders under section 143(3) read with section 147 of the Act/assessment order under section 143(3) of the Act were

S N BUILDERS & DEVELOPERS ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-4(3)(1), BANGALORE

In the result, the appeal filed by the assessee- company is allowed

Bench: Shri B.R. Baskaran & Shri Pavan Kumar Gadalem/S. S.N.Builders & Developers, No.4, 2Nd Floor, Elephant Rock Road, Above Kalayan Jewellers, Jayanagar 3Rd Block, Bengaluru-560 011. Pan: Abefs 8850 P … Appellant Vs. Asst. Commissioner Of Income-Tax, Circle 4(3)(1), Bengaluru. … Respondent Appellant By : Smt. Suman Lunkar, Ca. Respondent By : Shri Pradeep Kumar, Cit(Dr) Date Of Hearing: 07/11/2019 Date Of Pronouncement: 27/11/2019 O R D E R Per Pavan Kumar Gadale, Jm : The Assessee Has Filed Appeal Against The Order Of The Cit(A), Bangalore-9, Bangalore, Passed U/S 143(3) & 250 Of The Income-Tax Act,1961 ['The Act' For Short].

1). Therefore this court is required to give meaning and effect to the said expression. It follows, therefore, that the obligation to deduct TAS arises only when there is a sum chargeable under the Act. Section 195(2) is not merely a provision to provide information to the Income tax Officer (TDS

M/S TE CONNECTIVITY INDIA PRIVATE LIMITED,BANGALORE vs. CIT, BANGALORE

In the result, the appeal filed by the assessee-company is allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raom/S.Te Connectivity India Pvt. Ltd. ‘Te’ Park, 22B, Doddenakundi 2Nd Phase, Industrial Area, Whitefield Road, Bangalore-560048. … Appellant Pan: Aabct 7374 C Vs. Income-Tax Officer (Ltu)(Tds) Bangalore. … Respondent

1). Therefore this court is required to give meaning and effect to the said Page 7 of 13 expression. It follows, therefore, that the obligation to deduct TAS arises only when there is a sum chargeable under the Act. Section 195(2) is not merely a provision to provide information to the Income tax Officer (TDS

BOSCJ LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the appeal filed by the assessee company is treated as

Bench: Smt Asha Vijayaraghavan & Shri Inturi Rama Rao

1). Therefore this court is required to give meaning and effect to the said expression. It follows, therefore, that the obligation to deduct TAS arises only when there is a sum chargeable under the Act. Section 195(2) is not merely a provision to provide information to ITA No.1583(B)/2014 the Income tax Officer (TDS

DCIT, BANGALORE vs. M/S VODAFONE SOUTH LTD.,, NEW DELHI

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

TDS on such payment. But on the second aspect as to whether this payment is liable to tax or not in the hands of the recipients as FTS , as per Para 45, the tribunal remanded the matter back to CIT (A) for fresh adjudication because as per the earlier order which was before the tribunal, it was noted

VODAFONE SOUTH LIMITED,BANGALORE vs. DYDIT, BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

TDS on such payment. But on the second aspect as to whether this payment is liable to tax or not in the hands of the recipients as FTS , as per Para 45, the tribunal remanded the matter back to CIT (A) for fresh adjudication because as per the earlier order which was before the tribunal, it was noted

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(2) INTERNATIONAL TAXATION , BANGALORE vs. M/S VODAFONE SOUTH LTD , BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

TDS on such payment. But on the second aspect as to whether this payment is liable to tax or not in the hands of the recipients as FTS , as per Para 45, the tribunal remanded the matter back to CIT (A) for fresh adjudication because as per the earlier order which was before the tribunal, it was noted

M/S VODAFONE MOBILE SERVICES LIMITED ,BANGALORE vs. DEPUTY DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

TDS on such payment. But on the second aspect as to whether this payment is liable to tax or not in the hands of the recipients as FTS , as per Para 45, the tribunal remanded the matter back to CIT (A) for fresh adjudication because as per the earlier order which was before the tribunal, it was noted

M.S VODAFONE MOBILES SERVICES LIMITED ,BANGALORE vs. DEPUTY DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

TDS on such payment. But on the second aspect as to whether this payment is liable to tax or not in the hands of the recipients as FTS , as per Para 45, the tribunal remanded the matter back to CIT (A) for fresh adjudication because as per the earlier order which was before the tribunal, it was noted

JOINT COMMISSIONER OF INCOME TAX (OSD) CIRCLE-2(1)(IT), BANGALORE vs. M/S VODAFONE SOUTH LTD , BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

TDS on such payment. But on the second aspect as to whether this payment is liable to tax or not in the hands of the recipients as FTS , as per Para 45, the tribunal remanded the matter back to CIT (A) for fresh adjudication because as per the earlier order which was before the tribunal, it was noted

M/S VODAFONE MOBILE SERVICES LIMITED ,BANGALORE vs. DEPUTY DIRECTOR OF INCOME TAX (INTERNATIONAL TAXATION) CIRCLE-1(1), BANGALORE

In the result, all three Stay petitions are dismissed, five appeals of the assessee for A

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadale

TDS on such payment. But on the second aspect as to whether this payment is liable to tax or not in the hands of the recipients as FTS , as per Para 45, the tribunal remanded the matter back to CIT (A) for fresh adjudication because as per the earlier order which was before the tribunal, it was noted