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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

271(1)(c) of the Act (i. e, whether for concealment of income or for furnishing of inaccurate particulars) was not discernible from the penalty orders. 4.4.3 With respect to penalty levied under section 270A (AY 2017-18 to AY 2019-20) of the Act, the following specific submissions / contentions were made before the CIT(A): a) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i.e, whether for concealment of income or for furnishing of inaccurate particulars) was not discernible from the penalty orders. 4.4.3 With respect to penalty levied under section 270A (AY 2017-18 to AY 2019-20) of the Act, the following specific submissions / contentions were made before the CIT(A): a) Substantiating the ‘bonafide’ intention

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

271(1)(c) of the Act (i. e, whether for concealment of income or for furnishing of inaccurate particulars) was not discernible from the penalty orders. 4.4.3 With respect to penalty levied under section 270A (AY 2017-18 to AY 2019-20) of the Act, the following specific submissions / contentions were made before the CIT(A): a) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i. e, whether for concealment of income or for furnishing of inaccurate particulars) was not discernible from the penalty orders. 4.4.3 With respect to penalty levied under section 270A (AY 2017-18 to AY 2019-20) of the Act, the following specific submissions / contentions were made before the CIT(A): a) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i. e, whether for concealment of income or for furnishing of inaccurate particulars) was not discernible from the penalty orders. 4.4.3 With respect to penalty levied under section 270A (AY 2017-18 to AY 2019-20) of the Act, the following specific submissions / contentions were made before the CIT(A): a) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i. e, whether for concealment of income or for furnishing of inaccurate particulars) was not discernible from the penalty orders. 4.4.3 With respect to penalty levied under section 270A (AY 2017-18 to AY 2019-20) of the Act, the following specific submissions / contentions were made before the CIT(A): a) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i.e, whether for concealment of income or for furnishing of inaccurate particulars) was not discernible from the penalty orders. 4.4.3 With respect to penalty levied under section 270A (AY 2017-18 to AY 2019-20) of the Act, the following specific submissions / contentions were made before the CIT(A): a) Substantiating the ‘bonafide’ intention

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

271(1)(c) of the Act (i.e, whether for concealment of income or for furnishing of inaccurate particulars) was not discernible from the penalty orders. 4.4.3 With respect to penalty levied under section 270A (AY 2017-18 to AY 2019-20) of the Act, the following specific submissions / contentions were made before the CIT(A): a) Substantiating the ‘bonafide’ intention

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

271(1)(c) of the Act (i. e, whether for concealment of income or for furnishing of inaccurate particulars) was not discernible from the penalty orders. 4.4.3 With respect to penalty levied under section 270A (AY 2017-18 to AY 2019-20) of the Act, the following specific submissions / contentions were made before the CIT(A): a) Substantiating the ‘bonafide

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

271(1)(c) of the Act (i. e, whether for concealment of income or for furnishing of inaccurate particulars) was not discernible from the penalty orders. 4.4.3 With respect to penalty levied under section 270A (AY 2017-18 to AY 2019-20) of the Act, the following specific submissions / contentions were made before the CIT(A): a) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i. e, whether for concealment of income or for furnishing of inaccurate particulars) was not discernible from the penalty orders. 4.4.3 With respect to penalty levied under section 270A (AY 2017-18 to AY 2019-20) of the Act, the following specific submissions / contentions were made before the CIT(A): a) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i. e, whether for concealment of income or for furnishing of inaccurate particulars) was not discernible from the penalty orders. 4.4.3 With respect to penalty levied under section 270A (AY 2017-18 to AY 2019-20) of the Act, the following specific submissions / contentions were made before the CIT(A): a) Substantiating the ‘bonafide

TECNOTREE CONVERGENCE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-7(1)(1), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year : 2009-10

271(1)(c) was levied on the ground that the assessee violated of provisions of section 94(7) of the Act by not ignoring losses while computing short-term capital gains

SHRI. MUNINAGA REDDY,BANGALORE vs. ACIT, BANGALORE

In the result, the assessee's appeal for A

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

Capital Gains (LTCG) thereon; apart from declaring income / loss from other heads such as house property, business and other sources. The assessment was completed under section 143(3) of the Act by order dt.15.12.2008 wherein the income of the assessee was determined at Rs.5,45,59,686. Penalty proceedings under section 271(1)(c

GOPAL KRISHNA KARODI SABBANA,DAKSHINA KANNADA vs. DY./ASST.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, MANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

Capital Avenue Building Opp: STATE BANK MANGALURU-1 HAINYAN NOTARY. 06/10/25 ABDUL RAZAK G. REGD. No. 4129 MANGALORE D.K. Dist. KARNATAKA GOVT. OF INDIA Please write or type below this line AFFIDAVIT Errors & Corrections etc Nill/10/25 06 The authenticity of this Stamp certificate should be verified at 'www.shcilestamp.com' or using e-Stamp Mobile App of Stock Holding. Any discrepancy

DCIT vs. SRI. P. SUBRAMANI,

In the result, Revenue’s appeal for Assessment Year 2006-07 is dismissed

Bench: Shri Rajpal Yadav & Shri Jason P. Boaz

1)(c) of the Act, vide order dt.26.4.2012 only on the issue of denial of the assessee's claim for exemption under section 54B of the Act made in the computation of capital gains on sale of lands. 2.3 Aggrieved by the order dt.26.4.2012 levying penalty of Rs.10,24,846 under section 271

SIMPLEX TMC PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(1),BENGALURU, BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2018-19

Capital Gains. The AO further held that as the assessee had not offered the amount of Rs. 5,00,000/- as income, the undisclosed income is covered by provision of clause(b) Simplex TMC Pvt. Ltd., Bangalore Page 4 of 17 of Section 271AAB(1A) of the Act and accordingly a penalty

SMT B SUMATHY,BANGALORE vs. THE INCOME TAX OFFICER WARD-1(2)(2), BANGALORE

In the result, the assessee’s appeal for Assessment Year 2005-06 is allowed as indicated above

Bench: Shri N. V. Vasudevan & Shri Jason P Boazassessment Year : 2005-06 Smt. B. Sumathy, Vs. The Income Tax Officer, #T-401, Poorva Park, Ward – 1(2), Now Jeevana Halli Main Road, Ito, Ward – 1[2][2], Cox Town, Bangalore-560 005. Bangalore. Pan : Aseps 7079 K Appellant Respondent Assessee By : Shri. Narendra Sharma, Advocate Revenue By : Shri. T. Chandrasekhar, Addl. Cit Date Of Hearing : 27.03.2019 Date Of Pronouncement : 16.04.2019

capital gains by virtue of denying the assessee’s claim for exemption under section 54F of the Act. 3.2 Penalty proceedings under section 271(1)(c