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

property in question was found to be in the name of the wife of the assessee and the housing loan was also taken in her name. Therefore, the Assessing Officer disallowed these claims which resulted in addition to the assessee's income. The Assessing Officer simultaneously initiated penalty proceedings u/s. 271

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

SRI. NARASIMHA REDDY,BANGALORE vs. DCIT, BANGALORE

In the result, the appeals of the assessee are allowed

Bench: Shri Abraham P George & Shri Vijay Pal Rao

house property. There was a search u/s 132 of the IT Act on 26/8/2008 in the case of the assessee. During the course of search proceedings, certain incriminating documents belonging to the assessee were found and seized at his residential premises. Consequently proceedings u/s 153A of the Act were initiated. In the proceedings u/s 153A of the Act, the assessee

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

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 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 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 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 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 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

SRI. PANATI VIKRAMDEVA REDDY,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1), BENGALURU

In the result, the appeals of the assessee are dismissed

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahu

house property and thereafter declared undisclosed income for AY 2013-14 of Rs.17,09,973. The details called for were not provided by the assessee within stipulated time. Accordingly notice u/s 148 was issued to the assessee and in response the assessee did not file return of income. Notices u/s. 142(1) were issued on 12.11.2021, 16.12.2021 & 11.1.2021 for which

SRI. PANATI VIKRAMDEVA REDDY,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1), BENGALURU

In the result, the appeals of the assessee are dismissed

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahu

house property and thereafter declared undisclosed income for AY 2013-14 of Rs.17,09,973. The details called for were not provided by the assessee within stipulated time. Accordingly notice u/s 148 was issued to the assessee and in response the assessee did not file return of income. Notices u/s. 142(1) were issued on 12.11.2021, 16.12.2021 & 11.1.2021 for which

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

SRI. VINOD RADHAKRISHNA ,BENGALURU vs. THE INCOME TAX OFFICER, WARD-5(3)(4), BENGALURU

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalty order u/s 271(1)(c) of the Act for the AY 2014-15 by the AO by observing as follows: ITA Nos.207 to 209/Bang/2023 Sri Vinod Radhakrishna, Bengaluru Page 7 of 9 3.1 The ld. NFAC observed that the assessee has failed to prove his bona fides in so far as claiming bogus loss under the head House Property

SRI. VINOD RADHAKRISHNA ,BENGALURU vs. THE INCOME TAX OFFICER, WARD-5(3)(4), BENGALURU

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalty order u/s 271(1)(c) of the Act for the AY 2014-15 by the AO by observing as follows: ITA Nos.207 to 209/Bang/2023 Sri Vinod Radhakrishna, Bengaluru Page 7 of 9 3.1 The ld. NFAC observed that the assessee has failed to prove his bona fides in so far as claiming bogus loss under the head House Property

SRI. VINOD RADHAKRISHNA ,BENGALURU vs. THE INCOME TAX OFFICER, WARD-5(3)(4), BENGALURU

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalty order u/s 271(1)(c) of the Act for the AY 2014-15 by the AO by observing as follows: ITA Nos.207 to 209/Bang/2023 Sri Vinod Radhakrishna, Bengaluru Page 7 of 9 3.1 The ld. NFAC observed that the assessee has failed to prove his bona fides in so far as claiming bogus loss under the head House Property

SRI VENKATESWARA DEVELOPERS,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 7(2)(1), BANGALORE

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri George George K.

penalty u/s 271(1)(c) of the Act by furnishing inaccurate particulars of income to the extent of Rs.7,98,35,033/-. Further, he observed that assessee claimed deduction of interest payment of Rs.5,56,18,114/- u/s 24(b) of the ITA No.1910 & 2474/Bang/2019 Sri Venkateswara Developers, Bangalore Page 8 of 11 Act and Rs.2