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

Housing and Plantation Corporation (supra); in our view the issue regarding penalty u/s 27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page

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

Housing and Plantation Corporation (supra); in our view the issue regarding penalty u/s 27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page

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

Housing and Plantation Corporation (supra); in our view the issue regarding penalty u/s 27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page

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

Housing and Plantation Corporation (supra); in our view the issue regarding penalty u/s 27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page

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

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 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

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 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

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

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\n\nPage 26 of 56\n\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024

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

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\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

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

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 OSTERREICH INTIONATIONALE BUROMASCHINEN GESELLSCHAFT MBH,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\n\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024