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 AO as per section 197 of the Act in order to understand its tax liability. 4.2 Specific observation by the AO with respect to penalty under section 271(1)(c) of the Act 4.2.1 The AO in the penalty order has confirmed that the Assessee has ‘concealed’ particulars of income under section 271(1

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 AO as per section 197 of the Act in order to understand its tax liability. 4.2 Specific observation by the AO with respect to penalty under section 271(1)(c) of the Act 4.2.1 The AO in the penalty order has confirmed that the Assessee has ‘concealed’ particulars of income under section 271(1

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

The appeals of the assessees are allowed

TDS AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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 AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

MAHESH REDDY,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-2, BENGALURU

In the result, both the appeals of the assessee are allowed

263 smells of some degree of\ndiscretion given to the Commissioner for exercise of his revisionary\npowers, the same are not to be used arbitrarily and irrational\nmanner.\n6.23 Further, the judgements referred to as above, where it has\nbeen held that the Commissioner has to himself make enquiry in\norder to bring the error as well as the prejudice

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 AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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 AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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 AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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 AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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 AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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 AO as per\nsection 197 of the Act in order to understand its tax liability.\n\n4.2\nSpecific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n\n4.2.1\nThe AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1

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 AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

MAHESH REDDY ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(2)(1), BANGALORE

In the result, both the appeals of the assessee are allowed

263 smells of some degree of\ndiscretion given to the Commissioner for exercise of his revisionary\npowers, the same are not to be used arbitrarily and irrational\nmanner.\n6.23 Further, the judgements referred to as above, where it has\nbeen held that the Commissioner has to himself make enquiry in\norder to bring the error as well as the prejudice

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 AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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 AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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 AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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 AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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

The appeals of the assessees are allowed

TDS AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct