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

CHIGURUVADA DILEEPKUMAR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(3)(1), BENGALURU

In the result, the appeal filed by assessee in ITA No

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahu

Section 270A, and levying penalty. For these and other grounds that may be urged at the time of hearing of the appeal the 6. appellant prays that the appeal may be allowed The appellant craves leave to add, alter, delete 7. or substitute any of the grounds urged above. In view of the above and other grounds that

CHIGURUVADA DILEEP KUMAR ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(3)(1) , BANGALORE

In the result, the appeal filed by assessee in ITA No

Bench: Smt Beena Pillai & Shri Laxmi Prasad Sahu

Section 270A, and levying penalty. For these and other grounds that may be urged at the time of hearing of the appeal the 6. appellant prays that the appeal may be allowed The appellant craves leave to add, alter, delete 7. or substitute any of the grounds urged above. In view of the above and other grounds that

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 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 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 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 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 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

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 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

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

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\n\nPage 26 of 56\npenalties levied u/s 271(1)(c) and disputed in the present appeals before

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\n271(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 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

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