IBM ISRAEL 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 of the Act would not be of any relevance since the credit of taxes deducted under section 192 of the Act are given in the hands of the employees whereas the Assessee’s receipts were in nature of FTS. (Page 16-17 of the CIT(A) order) The CIT(A) has rejected the below Merely because

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 of the Act would not be of any relevance since the credit of taxes deducted under section 192 of the Act are given in the hands of the employees whereas the Assessee’s receipts were in nature of FTS. (Page 16-17 of the CIT(A) order) The CIT(A) has rejected the below Merely because

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 under section 192 of the Act would not be of any relevance since the credit of taxes deducted under section 192 of the Act are given in the hands of the employees whereas the Assessee’s receipts were in nature of FTS. (Page 16-17 of the CIT(A) order) The CIT(A) has rejected the below Merely because

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

1) of the Act has been filed however, secondment related\nreceipts were offered to tax only in the return filed under section\n148 of the Act\nObservation of the CIT(A)\nThe CIT(A) has rejected the submission of\nIBM in respect of discrepancies under\nwhich limb penalty is levied, basis the\nbelow contentions:\nThe provisions of section 270A

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

1) of the Act has been filed however, secondment related\nreceipts were offered to tax only in the return filed under section\n148 of the Act\nObservation of the CIT(A)\nThe CIT(A) has rejected the submission of\nIBM in respect of discrepancies under\nwhich limb penalty is levied, basis the\nbelow contentions:\n- The provisions of section 270A

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

1) of the Act has been filed however, secondment related\nreceipts were offered to tax only in the return filed under section\n148 of the Act\nObservation of the CIT(A)\nThe CIT(A) has rejected the submission of\nIBM in respect of discrepancies under\nwhich limb penalty is levied, basis the\nbelow contentions:\n- The provisions of section 270A

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

250 1,035 64,494 2016-17 1,51,475 36,336 2,167 630 10,299 2,03,255 Davangere: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/ s 194C u s 194C Total Interest Interest Interest TDS u/s TDS TDS 201(1A) 201(1A) deductibl 201 deductible deductible

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

250 1,035 64,494 2016-17 1,51,475 36,336 2,167 630 10,299 2,03,255 Davangere: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/ s 194C u s 194C Total Interest Interest Interest TDS u/s TDS TDS 201(1A) 201(1A) deductibl 201 deductible deductible

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

250 1,035 64,494 2016-17 1,51,475 36,336 2,167 630 10,299 2,03,255 Davangere: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/ s 194C u s 194C Total Interest Interest Interest TDS u/s TDS TDS 201(1A) 201(1A) deductibl 201 deductible deductible

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

250 1,035 64,494 2016-17 1,51,475 36,336 2,167 630 10,299 2,03,255 Davangere: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/ s 194C u s 194C Total Interest Interest Interest TDS u/s TDS TDS 201(1A) 201(1A) deductibl 201 deductible deductible

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

250 1,035 64,494 2016-17 1,51,475 36,336 2,167 630 10,299 2,03,255 Davangere: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/ s 194C u s 194C Total Interest Interest Interest TDS u/s TDS TDS 201(1A) 201(1A) deductibl 201 deductible deductible

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

250 1,035 64,494 2016-17 1,51,475 36,336 2,167 630 10,299 2,03,255 Davangere: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/ s 194C u s 194C Total Interest Interest Interest TDS u/s TDS TDS 201(1A) 201(1A) deductibl 201 deductible deductible

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

250 1,035 64,494 2016-17 1,51,475 36,336 2,167 630 10,299 2,03,255 Davangere: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/ s 194C u s 194C Total Interest Interest Interest TDS u/s TDS TDS 201(1A) 201(1A) deductibl 201 deductible deductible

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

250 1,035 64,494 2016-17 1,51,475 36,336 2,167 630 10,299 2,03,255 Davangere: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/ s 194C u s 194C Total Interest Interest Interest TDS u/s TDS TDS 201(1A) 201(1A) deductibl 201 deductible deductible

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

250 1,035 64,494 2016-17 1,51,475 36,336 2,167 630 10,299 2,03,255 Davangere: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/ s 194C u s 194C Total Interest Interest Interest TDS u/s TDS TDS 201(1A) 201(1A) deductibl 201 deductible deductible

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

250 1,035 64,494 2016-17 1,51,475 36,336 2,167 630 10,299 2,03,255 Davangere: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/ s 194C u s 194C Total Interest Interest Interest TDS u/s TDS TDS 201(1A) 201(1A) deductibl 201 deductible deductible

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

250 1,035 64,494 2016-17 1,51,475 36,336 2,167 630 10,299 2,03,255 Davangere: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/ s 194C u s 194C Total Interest Interest Interest TDS u/s TDS TDS 201(1A) 201(1A) deductibl 201 deductible deductible

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

250 1,035 64,494 2016-17 1,51,475 36,336 2,167 630 10,299 2,03,255 Davangere: Payment to Sodexo Cash Medical Payment to Chinnu SVC India Pvt Ltd Benefit u/s 192 Graphics u/ s 194C u s 194C Total Interest Interest Interest TDS u/s TDS TDS 201(1A) 201(1A) deductibl 201 deductible deductible