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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS. Furthermore, IBM India had duly deducted taxes under section 192 of the Act in respect of same secondment reimbursements. Given the same, there was no requirement on part of the IBM Foreign Entities to obtain a certificate under section 197

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. Furthermore, IBM India had duly deducted taxes under section 192 of the Act in respect of same secondment reimbursements. Given the same, there was no requirement on part of the IBM Foreign Entities to obtain a certificate under section 197

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. Furthermore, IBM India had duly deducted taxes under section 192 of the Act in respect of same secondment reimbursements. Given the same, there was no requirement on part of the IBM Foreign Entities to obtain a certificate under section 197

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. Furthermore, IBM India had duly deducted taxes under section 192 of the Act in respect of same secondment reimbursements. Given the same, there was no requirement on part of the IBM Foreign Entities to obtain a certificate under section 197

IBM ISRAEL 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. Furthermore, IBM India had duly deducted taxes under section 192 of the Act in respect of same secondment reimbursements. Given the same, there was no requirement on part of the IBM Foreign Entities to obtain a certificate under section 197

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. Furthermore, IBM India had duly deducted taxes under section 192 of the Act in respect of same secondment reimbursements. Given the same, there was no requirement on part of the IBM Foreign Entities to obtain a certificate under section 197

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS. Furthermore, IBM India had duly deducted taxes under section 192 of the Act in respect of same secondment reimbursements. Given the same, there was no requirement on part of the IBM Foreign Entities to obtain a certificate under section 197

COMPAGNIE IBM FRANCE,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. Furthermore, IBM India had duly deducted taxes under section 192 of the Act in respect of same secondment reimbursements. Given the same, there was no requirement on part of the IBM Foreign Entities to obtain a certificate under section 197

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

TDS. Furthermore, IBM India had duly deducted taxes under section 192 of the Act in respect of same secondment reimbursements. Given the same, there was no requirement on part of the IBM Foreign Entities to obtain a certificate under section 197

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. Furthermore, IBM India had duly deducted taxes under section 192 of the Act in respect of same secondment reimbursements. Given the same, there was no requirement on part of the IBM Foreign Entities to obtain a certificate under section 197

IBM AUSTRALIA 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. Furthermore, IBM India had duly deducted taxes under section 192 of the Act in respect of same secondment reimbursements. Given the same, there was no requirement on part of the IBM Foreign Entities to obtain a certificate under section 197

CEA SOMA CICI JV,BANGALORE vs. DCIT, BANGALORE

In the result, the assessee’s appeal is treated as allowed for

Bench: Shri. Vijay Pal Rao & Shri. S. Jayaraman

section 197 was effective from 03.09.2012 to 31.03.2013. The assessee had paid Rs.28,17,06,008/- between 01.04.2012 & 31.08.2012, the period at which the certificate u/s 197 was not effective , after deducting tax at 0.5%. In the proceedings u/ss 201(1) & 201(1A), the assessee submitted the following: 1. A part of the payment to CEC was towards adjustment

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

197 obtained by Sodexo SVC India Pvt. Ltd 2014-15 NA NA 8.4 NA 8.4 by exercising powers under section 133 (6) of the IT 2015-16 NA NA NA NA NA Act before treating the Appellant as assessee- 2016-17 NA NA 7.4 NA 7.4 indefault' under Section 201 (1) of the IT Act. 4.1. Referring to the above

M/S. LIFE INSURANCE CORPORATION OF INDIA,SHIVAMOGGA vs. THE INCOME TAX OFFICER (TDS) -WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

197 obtained by Sodexo SVC India Pvt. Ltd 2014-15 NA NA 8.4 NA 8.4 by exercising powers under section 133 (6) of the IT 2015-16 NA NA NA NA NA Act before treating the Appellant as assessee- 2016-17 NA NA 7.4 NA 7.4 indefault' under Section 201 (1) of the IT Act. 4.1. Referring to the above

M/S. LIFE INSURANCE CORPORATION OF INDIA,SHIVAMOGGA vs. THE INCOME TAX OFFICER (TDS) - WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

197 obtained by Sodexo SVC India Pvt. Ltd 2014-15 NA NA 8.4 NA 8.4 by exercising powers under section 133 (6) of the IT 2015-16 NA NA NA NA NA Act before treating the Appellant as assessee- 2016-17 NA NA 7.4 NA 7.4 indefault' under Section 201 (1) of the IT Act. 4.1. Referring to the above

M/S. LIFE INSURANCE CORPORATION OF INDIA,DAVANGERE vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

197 obtained by Sodexo SVC India Pvt. Ltd 2014-15 NA NA 8.4 NA 8.4 by exercising powers under section 133 (6) of the IT 2015-16 NA NA NA NA NA Act before treating the Appellant as assessee- 2016-17 NA NA 7.4 NA 7.4 indefault' under Section 201 (1) of the IT Act. 4.1. Referring to the above

M/S. LIFE INSURANCE CORPORATION OF INDIA,DAVANGERE vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

197 obtained by Sodexo SVC India Pvt. Ltd 2014-15 NA NA 8.4 NA 8.4 by exercising powers under section 133 (6) of the IT 2015-16 NA NA NA NA NA Act before treating the Appellant as assessee- 2016-17 NA NA 7.4 NA 7.4 indefault' under Section 201 (1) of the IT Act. 4.1. Referring to the above

M/S. LIFE INSURANCE CORPORATION OF INDIA,DAVANGERE vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

197 obtained by Sodexo SVC India Pvt. Ltd 2014-15 NA NA 8.4 NA 8.4 by exercising powers under section 133 (6) of the IT 2015-16 NA NA NA NA NA Act before treating the Appellant as assessee- 2016-17 NA NA 7.4 NA 7.4 indefault' under Section 201 (1) of the IT Act. 4.1. Referring to the above