M/S. PAUL RESORTS & HOTELS PVT LTD ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

penalty proceedings u/s 271(1)(c) of the Act is initiated separately. 14.5 With regard to Undisclosed income from transport business the ld. D.R. submitted that during the course of search, a document A/JDPL/12 was found and seized. It contained entries relating to income earned by the assessee while returning from the various ITA No.838 to 843/Bang/2023 M/s. Paul Resorts

M/S. PAUL RESORTS & HOTELS PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1) , BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

penalty proceedings u/s 271(1)(c) of the Act is initiated separately. 14.5 With regard to Undisclosed income from transport business the ld. D.R. submitted that during the course of search, a document A/JDPL/12 was found and seized. It contained entries relating to income earned by the assessee while returning from the various ITA No.838 to 843/Bang/2023 M/s. Paul Resorts

M/S. PAUL RESORTS & HOTELS PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

penalty proceedings u/s 271(1)(c) of the Act is initiated separately. 14.5 With regard to Undisclosed income from transport business the ld. D.R. submitted that during the course of search, a document A/JDPL/12 was found and seized. It contained entries relating to income earned by the assessee while returning from the various ITA No.838 to 843/Bang/2023 M/s. Paul Resorts

JOHN DEVELOPERS ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

penalty proceedings u/s 271(1)(c) of the Act is initiated separately. 14.5 With regard to Undisclosed income from transport business the ld. D.R. submitted that during the course of search, a document A/JDPL/12 was found and seized. It contained entries relating to income earned by the assessee while returning from the various ITA No.838 to 843/Bang/2023 M/s. Paul Resorts

M/S. PAUL RESORTS & HOTELS PVT. LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

penalty proceedings u/s 271(1)(c) of the Act is initiated separately. 14.5 With regard to Undisclosed income from transport business the ld. D.R. submitted that during the course of search, a document A/JDPL/12 was found and seized. It contained entries relating to income earned by the assessee while returning from the various ITA No.838 to 843/Bang/2023 M/s. Paul Resorts

JOHN DISTILLERIES PVT LTD.,,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(1), BANGALORE

In the result, appeals of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubey

penalty proceedings u/s 271(1)(c) of the Act is initiated separately. 14.5 With regard to Undisclosed income from transport business the ld. D.R. submitted that during the course of search, a document A/JDPL/12 was found and seized. It contained entries relating to income earned by the assessee while returning from the various ITA No.838 to 843/Bang/2023 M/s. Paul Resorts

INCOME TAX OFFICER, W-1, VIJAYANAGAR vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reopened by issuing notice u/s 153A of the Act on 13.3.2017 and the assessment for the assessment years 2013-14 & 2014-15 were framed u/s 143(3) r.w.s. 153A of the Act. The primary contention of the ld. A.R. is that in these two assessment years, the ld. AO made addition of Rs.2 Crores in the assessment year

M/S. S. RAMASHANDRA SETTY & SONS,HASSAN vs. INCOME TAX OFFICER, WARD-1 , HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reopened by issuing notice u/s 153A of the Act on 13.3.2017 and the assessment for the assessment years 2013-14 & 2014-15 were framed u/s 143(3) r.w.s. 153A of the Act. The primary contention of the ld. A.R. is that in these two assessment years, the ld. AO made addition of Rs.2 Crores in the assessment year

INCOME TAX OFFICER W 1, HASSAN vs. RAMACHANDRA SETTY AND SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reopened by issuing notice u/s 153A of the Act on 13.3.2017 and the assessment for the assessment years 2013-14 & 2014-15 were framed u/s 143(3) r.w.s. 153A of the Act. The primary contention of the ld. A.R. is that in these two assessment years, the ld. AO made addition of Rs.2 Crores in the assessment year

INCOME TAX OFFICER WARD-1 HASSAN, HASSAN vs. RAMACHANDRA SETTY AND SONGS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reopened by issuing notice u/s 153A of the Act on 13.3.2017 and the assessment for the assessment years 2013-14 & 2014-15 were framed u/s 143(3) r.w.s. 153A of the Act. The primary contention of the ld. A.R. is that in these two assessment years, the ld. AO made addition of Rs.2 Crores in the assessment year

INCOME TAX OFFICER, W-1, HASSAN vs. RAMACHANDRA SETTY & SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

reopened by issuing notice u/s 153A of the Act on 13.3.2017 and the assessment for the assessment years 2013-14 & 2014-15 were framed u/s 143(3) r.w.s. 153A of the Act. The primary contention of the ld. A.R. is that in these two assessment years, the ld. AO made addition of Rs.2 Crores in the assessment year

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

reopening the assessment. d) Reason for levy of penalty under section 270A of the Act (i.e, whether for underreporting of income or for underreporting of IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 22 of 56 income in consequence of misreporting) was not discernible from the penalty orders. e) Arbitrary reference

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

reopening the assessment. d) Reason for levy of penalty under section 270A of the Act (i.e, whether for underreporting of income or for underreporting of IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 22 of 56 income in consequence of misreporting) was not discernible from the penalty orders. e) Arbitrary reference

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

reopening the assessment. d) Reason for levy of penalty under section 270A of the Act (i.e, whether for underreporting of income or for underreporting of IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 22 of 56 income in consequence of misreporting) was not discernible from the penalty orders. e) Arbitrary reference

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

reopening the assessment. d) Reason for levy of penalty under section 270A of the Act (i.e, whether for underreporting of income or for underreporting of IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 22 of 56 income in consequence of misreporting) was not discernible from the penalty orders. e) Arbitrary reference

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

reopening the assessment.\nd) Reason for levy of penalty under section 270A of the Act (i.e,\nwhether for underreporting of income or for underreporting of\n\nPage 22 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\nincome in consequence of misreporting) was not discernible from\nthe penalty orders.\ne) Arbitrary

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

reopening the assessment.\nd) Reason for levy of penalty under section 270A of the Act (i.e,\nwhether for underreporting of income or for underreporting of\n\nPage 22 of 56\nincome in consequence of misreporting) was not discernible from\nthe penalty orders.\ne) Arbitrary reference to the term 'misreporting' without\nsubstantiating under which specific limb of section 270A

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

reopening the assessment.\nd) Reason for levy of penalty under section 270A of the Act (i.e,\nwhether for underreporting of income or for underreporting of\n\nPage 22 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\n\nincome in consequence of misreporting) was not discernible from\nthe penalty orders