BHADRAVATHI RAMALINGASETTY MANJUNATH SETTY,BHADRAVATHI vs. ITO WARD-1 TPS , SHIMOGA

In the result, appeal filed by the assessee is allowed

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2018-19

271-G' by Finance Act, 2015 (No. 20 of 2015), dated 14.5.2015.][, clause (c) or clause (d) of sub-section (1) or sub-section (2) of section 272-A, sub-section (1) of section 272-AA or ] [Inserted by Act 46 of 1986, Section 26 (w.e.f. 10.9.1986).][section 272-B or] [ Inserted by Act 20 of 2002, Section 106 (w.e.f

GOPAL KRISHNA KARODI SABBANA,DAKSHINA KANNADA vs. DY./ASST.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, MANGALORE

In the result, appeals filed by the assessee for all these AY are allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

10 of 16 health issues in all these years under consideration. The ld. AR of the assessee also drew our attention to the medical reports, various discharge summaries, Dialysis treatment record along with Echocardiogram report produced before us in order to substantiate that there was reasonable cause for delay filing of audit report

GOPAL KRISHNA KARODI SABBANA,DAKSHINA KANNADA vs. DY./ASST.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2,, MANGALORE

In the result, appeals filed by the assessee for all these AY are allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

10 of 16 health issues in all these years under consideration. The ld. AR of the assessee also drew our attention to the medical reports, various discharge summaries, Dialysis treatment record along with Echocardiogram report produced before us in order to substantiate that there was reasonable cause for delay filing of audit report

GOPAL KRISHNA KARODI SABBANA ,DAKSHINA KANNADA vs. DY./ASST.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, MANGALORE

In the result, appeals filed by the assessee for all these AY are allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

10 of 16 health issues in all these years under consideration. The ld. AR of the assessee also drew our attention to the medical reports, various discharge summaries, Dialysis treatment record along with Echocardiogram report produced before us in order to substantiate that there was reasonable cause for delay filing of audit report

GOPAL KRISHNA KARODI SABBANA,DAKSHINA KANNADA vs. DY./ASST.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, MANGALORE

In the result, appeals filed by the assessee for all these AY are allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

10 of 16 health issues in all these years under consideration. The ld. AR of the assessee also drew our attention to the medical reports, various discharge summaries, Dialysis treatment record along with Echocardiogram report produced before us in order to substantiate that there was reasonable cause for delay filing of audit report

SRI. CHINNAYELLAPPA CHANDRASHEKAR, ,BANGALORE vs. INCOME TAX OFFICER, WARD-4(2)(4), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

271-G' by Finance Act, 2015 (No. 20 of 2015), dated 14.5.2015.][, clause (c) or clause (d) of sub-section (1) or sub-section (2) of section 272-A, sub-section (1) of section 272-AA or ] [Inserted by Act 46 of 1986, Section 26 (w.e.f. 10.9.1986).][section 272-B or] [ Inserted by Act 20 of 2002, Section 106 (w.e.f

GOPAL KRISHNA KARODI SABBANA,DAKSHINA KANNADA vs. DY./ASST.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, MANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

10. Again, aggrieved by the order of ld. CIT(A)-2, Panaji, the assessee has filed the appeals for the assessment years 2015-16 to 2019-20 separately before us. The assessee has also filed consolidated paper book comprising 18 pages containing therein a copy of comparative year-wise chart of returns & tax audit filed, ITAT penalty order

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

26 of 56 penalties levied u/s 27l(l)(c) and disputed in the present appeals before us, are not sustainable. Accordingly, the penalties levied u/s 27l(l)(c) ofIT Act and disputed in the present appeals before us are hereby cancelled.” (Emphasis Supplied)  CIT vs Harsh International Pvt Ltd (ITA 620/2019, 622/2019 and CM Appl 30811/2019, 301813/2019) “Having heard

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

26 of 56 penalties levied u/s 27l(l)(c) and disputed in the present appeals before us, are not sustainable. Accordingly, the penalties levied u/s 27l(l)(c) ofIT Act and disputed in the present appeals before us are hereby cancelled.” (Emphasis Supplied)  CIT vs Harsh International Pvt Ltd (ITA 620/2019, 622/2019 and CM Appl 30811/2019, 301813/2019) “Having heard

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

26 of 56 penalties levied u/s 27l(l)(c) and disputed in the present appeals before us, are not sustainable. Accordingly, the penalties levied u/s 27l(l)(c) ofIT Act and disputed in the present appeals before us are hereby cancelled.” (Emphasis Supplied)  CIT vs Harsh International Pvt Ltd (ITA 620/2019, 622/2019 and CM Appl 30811/2019, 301813/2019) “Having heard

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

26 of 56 penalties levied u/s 27l(l)(c) and disputed in the present appeals before us, are not sustainable. Accordingly, the penalties levied u/s 27l(l)(c) ofIT Act and disputed in the present appeals before us are hereby cancelled.” (Emphasis Supplied)  CIT vs Harsh International Pvt Ltd (ITA 620/2019, 622/2019 and CM Appl 30811/2019, 301813/2019) “Having heard

IBM UNITED KINGDOM LIMITED,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

26 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others penalties levied u/s 271(1)(c) and disputed in the present appeals before us, are not sustainable. Accordingly, the penalties levied u/s 271(1)(c) ofIT Act and disputed in the present appeals before us are hereby cancelled.” (Emphasis Supplied

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

10 to AY 2015-16, wherein tax liability of approximately Rs 83 crore was duly paid by IBM India as per the VsV Scheme and the litigation pertaining to seven years was settled to end litigation and attain closure. 3.14 IBM India, on acceptance of the said receipts to tax in India, withdrew its pending appeals before the ITAT (Special

SHRI S KRISHNA PRASAD ,BALLARI vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE, BELAGAVI

In the result, all the appeals of the assessee are treated as allowed

Bench: Shri B.R Baskaran & Shri Pavan Kumar Gadale

10-11-2017), wherein the penalty levied u/s 271AAB was confirmed. The Ld D.R also placed his reliance on the decision rendered by Hon'ble Delhi High Court in the case of Pr. CIT vs. Smt. Ritu Singhal (ITA 672/2016 dated 12-03-2018) rendered in the context of provisions of sec.271AAA of the Act. He submitted that the principles

COMPAGNIE IBM FRANCE,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

10 to AY 2015-16, wherein tax liability of approximately Rs 83 crore was duly paid by IBM India as per the VsV Scheme and the litigation pertaining to seven years was settled to end litigation and attain closure. 3.14 IBM India, on acceptance of the said receipts to tax in India, withdrew its pending appeals before the ITAT (Special

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

10 to AY 2015-16, wherein tax liability of approximately Rs 83 crore was duly paid by IBM India as per the VsV Scheme and the litigation pertaining to seven years was settled to end litigation and attain closure. 3.14 IBM India, on acceptance of the said receipts to tax in India, withdrew its pending appeals before the ITAT (Special

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

10 to AY 2015-16, wherein tax liability of approximately Rs 83 crore was duly paid by IBM India as per the VsV Scheme and the litigation pertaining to seven years was settled to end litigation and attain closure. 3.14 IBM India, on acceptance of the said receipts to tax in India, withdrew its pending appeals before the ITAT (Special

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

10 to AY 2015-16, wherein tax liability of approximately Rs 83 crore was duly paid by IBM India as per the VsV Scheme and the litigation pertaining to seven years was settled to end litigation and attain closure. 3.14 IBM India, on acceptance of the said receipts to tax in India, withdrew its pending appeals before the ITAT (Special