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(1)(c

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(1)(c

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(1)(c

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(1)(c

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(1)(c

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

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(1)(c

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

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

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(1)(c

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(1)(c

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(1)(c

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(1)(c

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

M/S. SRI. MUTHU CINE SERVICE,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2(1), BENGALURU

In the result, all these appeals filed by the assessee are allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

271(1)(c)/270A of the Act 6. 6 months from the 31.12.2021 31.12.2021 31.12.2021 31.12.2021 31.12.2021 end of the month in which action for imposition of penalty initiated 7. Decision Time barred Time Time barred Time barred Time barred barred M/s. Sri Muthu Cine Service, Bangalore 6.1 Before proceeding further, it is apposite here to take note of section

M/S. SRI. MUTHU CINE SERVICE,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BENGALURU

In the result, all these appeals filed by the assessee are allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

271(1)(c)/270A of the Act 6. 6 months from the 31.12.2021 31.12.2021 31.12.2021 31.12.2021 31.12.2021 end of the month in which action for imposition of penalty initiated 7. Decision Time barred Time Time barred Time barred Time barred barred M/s. Sri Muthu Cine Service, Bangalore 6.1 Before proceeding further, it is apposite here to take note of section

IBM DEL PERU SAC,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

TDS under\nsection 192 in respect of all the salaries of the seconded employees,\nin respect of which costs were reimbursed to the IBM foreign\ncompanies; Thereafter, reassessment/ assessment proceedings were\nconducted on the IBM foreign entities and reassessment orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were

M/S. SRI. MUTHU CINE SERVICE,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BENGALURU

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

271(1)(c)/270A the Act of 6. 6 months from the 31.12.2021 end of the month in which action for imposition of penalty initiated 7. Decision 14.01.2022 14.01.2022 14.01.2022 14.01.2022 Rs.83,430/- Rs.1,33,488/- Rs.3,53,187/- Rs.4,20,586/- 15.02.2022 15.02.2022 15.02.2022 15.02.2022 31.12.2021 31.12.2021 31.12.2021 31.12.2021 Time barred Time barred Time barred Time barred Time barred

M/S SYNDICATE BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS) RANGE-3 , BANGALORE

In the result, all the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazin Ita Nos. A.Y. Appellant(S) Vs. Respondent 709/Bang/2019 2012-13 Syndicate Bank, 2011-12 Rajajinagar Main Branch, Ramamandir Road, 3Rd Block, Rajajinagar, Bangalore – 560 010. Tan : Blrs 00880 F Pan: Aaccs 4699E 710/Bang/2019 2011-12 Syndicate Bank, 735/Bang/2019 2013-14 Jayanagar Market Complex Branch, The Assistant 12Th Main Road, Commissioner Of 3Rd Block, Jayanagar, Income Tax (Tds), Bangalore-560 011. Tan : Blrs 16148 G Range 3, Pan: Aaccs 4699E Bangalore. 711/Bang/2019 2011-12 Syndicate Bank, 2013-14 Bit Branch, K.R. Road,V V Puram, Bangalore-560 004. Tan : Blrs 16186 C Pan: Aaccs 4699E 712/Bang/2019 2011-12 Syndicate Bank, Vijaya College Br., R V Road, Basavangudi Bangalore – 560 004. Tan : Blrs 15334 E Pan: Aaccs 4699E

271, section 271A, section 271AA, section 271B , section 271BA, section 271BB, section 271C, section 271CA, section 271D, section 271E, section 271F, section 271FA, section 271FB, section 271G, section 271H, clause (c) or clause (d) of sub section (1) or sub-section (2) of section 272A, sub-section (1) of section 272AA or section 272B or subsection (1) or subsection