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

house property; ii) Disallowance of deduction u/s.80C of Rs.1,00,000. iii) Disallowance of cost of improvement to the tune of Rs.1,56,98,159 in computing LTCG. iv) Disallowance of deduction u/s.54B of the Act to the extent of Rs.3,68,14,038. Penalty proceedings under section 271(1)(c) of the Act was initiated simultaneously

EXPAT ENGINEERING INDIA LIMITED,BENGALURU vs. ACIT, CIRCLE-2(1)(2), BENGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2014-15

Housing Corpn (2010) 193 Taxman 193 (SC) (ii) Velliappa Textiles Ltd (2003) 132 taxman 165 (SC) (iii) Babita Lila (2016) 73 taxmann.com 32 (SC) 36. In our considered view this contention of the ld AR is completely out of context as we have already held that Sec.40(a)(ii) is not relevant to the present issue before

SMT.KONDAMMA ,BANGALORE ` vs. INCOME TAX OFFICER WARD-6(2)(4), BANGALORE

In the result, the appeal filed by the assessee is allowed

Bench: Shri Arun Kumar Garodia & Smt. Beena Pillaiassessment Year : 2012-13 Smt. Kondamma, No. 122/2, 6Th Main, The Income Tax Opp Srs Printer, Officer, Kammagondanhalli, Vs. Ward – 6 (2) (4), Jalahalli West, Bangalore. Bangalore – 560 015. Pan: Atypk2334A Appellant Respondent Assessee By : Shri H. Guruswamy, Itp Revenue By : Shri R.N. Siddappaji, Addl. Cit (Dr) Date Of Hearing : 04.09.2019 Date Of Pronouncement : 13.09.2019

section shall affect the rights of a transferee for consideration who has no notice of the contract or of the part performance thereof.] Page 6 of 9 From the above provision it is clear that the key element in the transfer in part performance of a contract is the taking over of possession of the property by the transferee

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

Housing and\nPlantation Corporation (supra); in our view the issue regarding penalty u/s\n27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of\nthe assessee by the aforesaid orders; and, therefore, we hold that the\nPage 26 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada

THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU vs. M/S. BLUELINE FOODS (INDIA) PVT. LTD.,, MANGALURU

property. The mere issue of warrant of authorization\nwithout there being search of the premises mentioned in the warrant\nof authorization would be meaningless and would not serve the\npurpose of section 132 of the Act. It may be illustrated by taking an\nexample that if warrant of authorization under section 132 is issued in\nthe name of “A” after

M/S. GLOBAL STAR REALTORS PRIVATE LIMITED,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALORE

In the result, all the appeals of the assessee are partly\nallowed

house property, and, accordingly, this\npaper is liable to be ignored.\ng. In Devilal Gherilal Shah v. Dy. CIT/1995/52 TTJ\n(Aha'.) 618, the Tribunal held that no date or name is\nmentioned on the seized paper. In such a case, it is very\ndifficult to say that the assessee purchased gold\nornaments and, therefore, he should be assessed

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

Housing and\nPlantation Corporation (supra); in our view the issue regarding penalty u/s\n27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of\nthe assessee by the aforesaid orders; and, therefore, we hold that the\nPage 26 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada

M/S. GLOBAL STAR REALTORS PRIVATE LIMITED ,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU

In the result, all the appeals of the assessee are partly\nallowed

house property, and, accordingly, this\npaper is liable to be ignored.\ng. In Devilal Gherilal Shah v. Dy. CIT/1995/52 TTJ\n(Aha'.) 618, the Tribunal held that no date or name is\nmentioned on the seized paper. In such a case, it is very\ndifficult to say that the assessee purchased gold\nornaments and, therefore, he should be assessed

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

Housing and\nPlantation Corporation (supra); in our view the issue regarding penalty u/s\n27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of\nthe assessee by the aforesaid orders; and, therefore, we hold that the\nPage 26 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada

M/S. GLOBAL STAR REALTORS PRIVATE LIMITED,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU

In the result, all the appeals of the assessee are partly\nallowed

house property, and, accordingly, this\npaper is liable to be ignored.\ng. In Devilal Gherilal Shah v. Dy. CIT/1995/52 TTJ\n(Aha'.) 618, the Tribunal held that no date or name is\nmentioned on the seized paper. In such a case, it is very\ndifficult to say that the assessee purchased gold\nornaments and, therefore, he should be assessed

M/S. GLOBAL STAR REALTORS PRIVATE LIMITED,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU

In the result, all the appeals of the assessee are partly\nallowed

house property, and, accordingly, this\npaper is liable to be ignored.\ng. In Devilal Gherilal Shah v. Dy. CIT/1995/52 TTJ\n(Aha'.) 618, the Tribunal held that no date or name is\nmentioned on the seized paper. In such a case, it is very\ndifficult to say that the assessee purchased gold\nornaments and, therefore, he should be assessed

M/S. GLOBAL STAR REALTORS PRIVATE LIMITED ,UDUPI vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1, MANGALURU

In the result, all the appeals of the assessee are partly\nallowed

house property, and, accordingly, this\npaper is liable to be ignored.\ng. In Devilal Gherilal Shah v. Dy. CIT/1995/52 TTJ\n(Aha'.) 618, the Tribunal held that no date or name is\nmentioned on the seized paper. In such a case, it is very\ndifficult to say that the assessee purchased gold\nornaments and, therefore, he should be assessed

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

Housing and\nPlantation Corporation (supra); in our view the issue regarding penalty u/s\n27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of\nthe assessee by the aforesaid orders; and, therefore, we hold that the\nPage 26 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada

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

Housing and\nPlantation Corporation (supra); in our view the issue regarding penalty u/s\n27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of\nthe assessee by the aforesaid orders; and, therefore, we hold that the\n\nPage 26 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM

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

Housing and\nPlantation Corporation (supra); in our view the issue regarding penalty u/s\n27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of\nthe assessee by the aforesaid orders; and, therefore, we hold that the\nPage 26 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada

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

Housing and\nPlantation Corporation (supra); in our view the issue regarding penalty u/s\n27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of\nthe assessee by the aforesaid orders; and, therefore, we hold that the\n\nPage 26 of 56\npenalties levied u/s 271(1)(c) and disputed in the present appeals before

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

Housing and\nPlantation Corporation (supra); in our view the issue regarding penalty u/s\n271(1)(c) of IT Act disputed in the appeals before us is covered in favour of\nthe assessee by the aforesaid orders; and, therefore, we hold that the\nPage 26 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada

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

Housing and\nPlantation Corporation (supra); in our view the issue regarding penalty u/s\n27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of\nthe assessee by the aforesaid orders; and, therefore, we hold that the\nPage 26 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada