SRI. CHANDRAKANT SHAMAPPA KONTHA,HUBLI vs. DCIT, CIRCLE-1 & TPS, HUBLI

In the result both the appeals are allowed for statistical purposes

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

house property, income from business and income from other ITA No. 2396 & 2397/ bang/2024 A Y : 2019-20 & 2020-21 Shri Chandrakant Shamappa Kpntha Versus DCIT Circle (1) (1) & TPS Hubli sources. This return of income was processed under section 143

SRI. CHANDRAKANT SHAMAPPA KONTHA,HUBLI vs. DCIT, CIRCLE-1(1) & TPS, HUBLI

In the result both the appeals are allowed for statistical purposes

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

house property, income from business and income from other ITA No. 2396 & 2397/ bang/2024 A Y : 2019-20 & 2020-21 Shri Chandrakant Shamappa Kpntha Versus DCIT Circle (1) (1) & TPS Hubli sources. This return of income was processed under section 143

DCIT CIRCLE-3(1)91), BENGALURU vs. G CORP PRIVATE LIMITED, BANGALORE

In the result is filed by the learned assessing officer is allowed

Bench: Shri Prashant Maharishi, Vice – & Shri Keshav Dubeyassessment Year : 2014-15

1 MG Mall as house property income. xxiii. Pursuant to the same, the learned assessing officer passed an assessment order under section 143

BINDUMALYAM PANDURANGA ALLANHARINARAYAN ,BANGALORE vs. INCOME TAX OFFICER, WARD-5(2)(1), BENGALURU

In the result, appeal filed by the assessee is partly\nallowed

property was not let for the entire year.", "result": "Partly Allowed", "sections": [ "143(1)", "143(2)", "142(1)", "44AD", "23(1)(a)", "23(1)(c)", "24(a)", "22", "28", "143(3)" ], "issues": "1. Whether maintenance charges received by the assessee are business income or income from house

KARNATAKA CHINMAYA SEVA TRUST,BENGALURU vs. DCIT-(EXEMPTIONS) CIRCLE-1, BANGALORE

In the result, the appeal of the assessee in ITA No

Section 143(1) on 31.03.2013.The case was selected by\nRevenue for framing scrutiny assessment under CASS, and statutory notices under\nSection 143(2) and 142(1) were issued by the ld. Assessing Officer, during the\ncourse of assessment proceedings. The objects of the assessee as per assessee trust\ndeed reads as under:-\n“(i) To conduct study groups, lecture series

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

143(1)(a) of the Act on 15-3-1999. Subsequently, on the basis of some information with regard to sale proceeds of the shares amounting to Rs. 32,40,385 on which the capital gain was declared at Rs. 29,74,951 by the assessee in the original return, a notice under section 148 of the Act was issued

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

143(1)(a) of the Act on 15-3-1999. Subsequently, on the basis of some information with regard to sale proceeds of the shares amounting to Rs. 32,40,385 on which the capital gain was declared at Rs. 29,74,951 by the assessee in the original return, a notice under section 148 of the Act was issued

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

143(1)(a) of the Act on 15-3-1999. Subsequently, on the basis of some information with regard to sale proceeds of the shares amounting to Rs. 32,40,385 on which the capital gain was declared at Rs. 29,74,951 by the assessee in the original return, a notice under section 148 of the Act was issued

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

143(1)(a) of the Act on 15-3-1999. Subsequently, on the basis of some information with regard to sale proceeds of the shares amounting to Rs. 32,40,385 on which the capital gain was declared at Rs. 29,74,951 by the assessee in the original return, a notice under section 148 of the Act was issued

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

143(1)(a) of the Act on 15-3-1999.\nSubsequently, on the basis of some information with regard to sale\nproceeds of the shares amounting to Rs. 32,40,385 on which the\ncapital gain was declared at Rs. 29,74,951 by the assessee in the\noriginal return, a notice under section 148 of the Act was issued

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

143(1)(a) of the Act on 15-3-1999.\nSubsequently, on the basis of some information with regard to sale\nproceeds of the shares amounting to Rs. 32,40,385 on which the\ncapital gain was declared at Rs. 29,74,951 by the assessee in the\noriginal return, a notice under section 148 of the Act was issued

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

143(1)(a) of the Act on 15-3-1999.\nSubsequently, on the basis of some information with regard to sale\nproceeds of the shares amounting to Rs. 32,40,385 on which the\ncapital gain was declared at Rs. 29,74,951 by the assessee in the\noriginal return, a notice under section 148 of the Act was issued

M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

Bench: Shri Chandra Poojari & Shri George George K.

Housing Development Company supra, in support of the contention that search under Section 132 of the Act is sine qua non for initiation of proceedings under Section 153A of the Act but it is not dependent on any undisclosed income being unearthed during search. There is no cavil on this proposition that search under Section 132 or requisition under 132A

M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

Bench: Shri Chandra Poojari & Shri George George K.

Housing Development Company supra, in support of the contention that search under Section 132 of the Act is sine qua non for initiation of proceedings under Section 153A of the Act but it is not dependent on any undisclosed income being unearthed during search. There is no cavil on this proposition that search under Section 132 or requisition under 132A

M/S. TRISHUL BUILDTECH & INFRASTRUCTURES PVT. LTD.,,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(2), BENGALURU

In the result, assessee’s appeals are partly allowed

Bench: Shri Chandra Poojari & Shri George George K.

Housing Development Company supra, in support of the contention that search under Section 132 of the Act is sine qua non for initiation of proceedings under Section 153A of the Act but it is not dependent on any undisclosed income being unearthed during search. There is no cavil on this proposition that search under Section 132 or requisition under 132A

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

143(1)(a) of the Act on 15-3-1999.\nSubsequently, on the basis of some information with regard to sale\nproceeds of the shares amounting to Rs. 32,40,385 on which the\ncapital gain was declared at Rs. 29,74,951 by the assessee in the\noriginal return, a notice under section 148 of the Act was issued

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

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

143(1)(a) of the Act on 15-3-1999.\nSubsequently, on the basis of some information with regard to sale\nproceeds of the shares amounting to Rs. 32,40,385 on which the\ncapital gain was declared at Rs. 29,74,951 by the assessee in the\noriginal return, a notice under section 148 of the Act was issued

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

143(1)(a) of the Act on 15-3-1999.\nSubsequently, on the basis of some information with regard to sale\nproceeds of the shares amounting to Rs. 32,40,385 on which the\ncapital gain was declared at Rs. 29,74,951 by the assessee in the\noriginal return, a notice under section 148 of the Act was issued