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 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 CHINA HONG KONG LIMITED,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

TDS. Furthermore, IBM India had duly deducted taxes\nunder section 192 of the Act in respect of same secondment\nreimbursements. Given the same, there was no requirement on part\nof 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

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

TDS. Furthermore, IBM India had duly deducted taxes\nunder section 192 of the Act in respect of same secondment\nreimbursements. Given the same, there was no requirement on part\nof 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

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

TDS. Furthermore, IBM India had duly deducted taxes\nunder section 192 of the Act in respect of same secondment\nreimbursements. Given the same, there was no requirement on part\nof 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

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

TDS. Furthermore, IBM India had duly deducted taxes\nunder section 192 of the Act in respect of same secondment\nreimbursements. Given the same, there was no requirement on part\nof 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

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

TDS. Furthermore, IBM India had duly deducted taxes\nunder section 192 of the Act in respect of same secondment\nreimbursements. Given the same, there was no requirement on part\nof 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

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

TDS. Furthermore, IBM India had duly deducted taxes\nunder section 192 of the Act in respect of same secondment\nreimbursements. Given the same, there was no requirement on part\nof 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

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

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

IBM OSTERREICH INTIONATIONALE BUROMASCHINEN GESELLSCHAFT MBH,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

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

TDS. Furthermore, IBM India had duly deducted taxes\nunder section 192 of the Act in respect of same secondment\nreimbursements. Given the same, there was no requirement on part\nof 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

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

TDS. Furthermore, IBM India had duly deducted taxes\nunder section 192 of the Act in respect of same secondment\nreimbursements. Given the same, there was no requirement on part\nof 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

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

TDS. Furthermore, IBM India had duly deducted taxes\nunder section 192 of the Act in respect of same secondment\nreimbursements. Given the same, there was no requirement on part\nof 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

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

TDS. Furthermore, IBM India had duly deducted taxes\nunder section 192 of the Act in respect of same secondment\nreimbursements. Given the same, there was no requirement on part\nof 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

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

TDS. Furthermore, IBM India had duly deducted taxes\nunder section 192 of the Act in respect of same secondment\nreimbursements. Given the same, there was no requirement on part\nof 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

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

TDS. Furthermore, IBM India had duly deducted taxes\nunder section 192 of the Act in respect of same secondment\nreimbursements. Given the same, there was no requirement on part\nof 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

The appeals of the assessees are allowed

TDS. Furthermore, IBM India had duly deducted taxes\nunder section 192 of the Act in respect of same secondment\nreimbursements. Given the same, there was no requirement on part\nof 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

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

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

IBM DEUTSCHLAND GMBH,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

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