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

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

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

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

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

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

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

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

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

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

SRI SURYANARAYANA GNANESHWARA RAO ,BANGALORE vs. INCOME TAX OFFICER WARD-1(2), BANGALORE

In the result appeal filed by assessee stands allowed

Bench: Shri A.K.Garodia & Smt.Beena Pillai, Judical Member Ita No.3274(Bang)/2018 (Assessment Year : 2007-08) Shri Suryanarayana Gnaneshwara Rao, No.83, Nisa Enclave, Mm Road, Fraser Town, Bangalore-560 005 Panno.Aempr9001C Appellant Vs The Income Tax Officer, Ward-1(2), Bangalore Respondent Appellant By : Smt. Jinita Chatterjee, Advocate Revenue By : Shri Praveen Karanth, Addl. Cit

section 271(1)(c ) of the Act. v. Without prejudice, he Assessing Officer ought to have appreciated that just because the deductor had issued TDS

ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PVT LTD ,BANGALORE vs. INCOME TAX OFFICER (TDS) /OSD , BANGALORE

In the result, both the appeals filed by assessee stands allowed for statistical purposes

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

TDS provisions on disallowance of the expenditure in question under section 40(a)(i)/(ia) of the Act. This rational is based on the scheme of Section 40(a)(i)/(ia), which is aimed at ensuring that an expenditure should not be allowed as deduction in the hands of an assessee(deductor) in a situation in which income embedded

ROBERT BOSCH ENGINEERING AND BUSINESS SOLUTIONS PRIAVTE LIMITED ,BANGALORE vs. INCOME TAX OFFICER (TDS) /OSD LTU , BANGALORE

In the result, both the appeals filed by assessee stands allowed for statistical purposes

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

TDS provisions on disallowance of the expenditure in question under section 40(a)(i)/(ia) of the Act. This rational is based on the scheme of Section 40(a)(i)/(ia), which is aimed at ensuring that an expenditure should not be allowed as deduction in the hands of an assessee(deductor) in a situation in which income embedded

DELL INTERNATIONAL SERVICES INDIA PVT. LTD.,,BANGALORE vs. ITO, BANGALORE

In the result the appeals filed by assessee and revenue for A

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

TDS provisions on disallowance of the expenditure in question under section 40(a)(i)/(ia) of the Act. This rational is based on the scheme of Section 40(a)(i)/(ia), which is aimed at ensuring that an expenditure should not be allowed as deduction in the hands of an assessee(deductor) in a situation in which income embedded