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 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

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

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

JOINT COMMISSIONER OF INCOME TAX, BANGALORE vs. M/S STATE BANK OF MYSORE, H EAD OFFICE,, BANGALORE

In the result, the assessee's appeals for Assessment Years 2006-07 to 2008-09 are allowed and Revenue’s appeals for Assessment Years 2006-07 and 2008-09 are dismissed

Bench: Shri George George K & Shri Jason P. Boazi.T. A. Nos.1079 & 1080/Bang/2014 (Assessment Years : 2006-07 & 2008-09)

Section 271(1)(c) of the Act for Assessment Years 2006-07 to 2008-09, the assessee preferred appeals before the CIT (Appeals), LTU, Bangalore. The learned CIT (Appeals) vide the impugned order dt.27.6.2014 passed a common order for the aforesaid three assessment years, confirming the levy of penalty on certain issues and deleting the penalty on certain other issues

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

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

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

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

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

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

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

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

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

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

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

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

M/S. CHILD DEVELOPMENT PROJECT OFFICER,SHIVAMOGGA vs. INCOME-TAX OFFICER, TDS WARD, DAVANGERE

The appeals are partly allowed to the aforesaid extent

Bench: Shri George George Kshri Laxmi Prasad Sahu

TDS after 1-7-2012.[Para 18] Hence, it can be said that, the mechanism provided for enforceability of section 200(3) or section 206C (3) for filing of the statement by making it penal under section 272A(2)(k) is done away in view of the insertion of section 271

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