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

112-141 of case law reassessment proceedings. compilation wherein the SC (at page 117) - Reference to Explanation 3 to section has dealt with the aspect of ‘reasonable 271(1)(c) of the Act was upheld cause”. The Supreme Court has held that where there are contradictory judicial (Page 10/11 of the CIT(A)’s order) pronouncements on an issue, that

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

112-141 of case law reassessment proceedings. compilation wherein the SC (at page 117) - Reference to Explanation 3 to section has dealt with the aspect of ‘reasonable 271(1)(c) of the Act was upheld cause”. The Supreme Court has held that where there are contradictory judicial (Page 10/11 of the CIT(A)’s order) pronouncements on an issue, that

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

u/s 271(1)(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 the learned counsel for the appellant and having perused the impugned order, this Court is of the view that the ITAT was right in deleting

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

u/s 271(1)(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 the learned counsel for the appellant and having perused the impugned order, this Court is of the view that the ITAT was right in deleting

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

u/s 271(1)(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 the learned counsel for the appellant and having perused the impugned order, this Court is of the view that the ITAT was right in deleting

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

u/s 271(1)(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 the learned counsel for the appellant and having perused the impugned order, this Court is of the view that the ITAT was right in deleting

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

u/s 271(1)(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 the learned counsel for the appellant and having perused the impugned order, this Court is of the view that the ITAT was right in deleting

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

u/s 271(1)(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 the learned counsel for the appellant and having perused the impugned order, this Court is of the view that the ITAT was right in deleting

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

u/s 271(1)(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 the learned counsel for the appellant and having perused the impugned order, this Court is of the view that the ITAT was right in deleting

IBM AUSTRALIA 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

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 the learned counsel for the appellant and having perused the impugned order, this Court is of the view that the ITAT was right in deleting

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

u/s 271(1)(c) ofIT Act\nand disputed in the present appeals before us are hereby cancelled.\"\n(Emphasis Supplied)\nCIT vs Harsh International Pvt Ltd (ITA 620/2019, 622/2019 and CM\nAppl 30811/2019, 301813/2019)\n“Having heard the learned counsel for the appellant and having perused the\nimpugned order, this Court is of the view that the ITAT was right

M/S. SYNDICATE BANK,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), RANGE- 3, BANGALORE

In the result, all the appeals by the assessees are allowed

Bench: Shri N.V. Vasudevan & Shri B.R.Baskaran

112, J C Road, Bangalore. Bangalore – 560 002. TAN : BLRS 14425F PAN: AAACC 6106G Appellant by : Mr. S. Ananthan & Ms. Lalitha Rameswaran, CAs Respondent by : Ms. R. Premi, JCIT SR.DR(ITAT), Bengaluru. Date of hearing : 01.10.2020 Date of Pronouncement : 05.10.2020 O R D E R Per N.V. Vasudevan, Vice President These are all appeals by the Assessee, a nationalised bank

M/S. SYNDICATE BANK,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), RANGE- 3, BANGALORE

In the result, all the appeals by the assessees are allowed

Bench: Shri N.V. Vasudevan & Shri B.R.Baskaran

112, J C Road, Bangalore. Bangalore – 560 002. TAN : BLRS 14425F PAN: AAACC 6106G Appellant by : Mr. S. Ananthan & Ms. Lalitha Rameswaran, CAs Respondent by : Ms. R. Premi, JCIT SR.DR(ITAT), Bengaluru. Date of hearing : 01.10.2020 Date of Pronouncement : 05.10.2020 O R D E R Per N.V. Vasudevan, Vice President These are all appeals by the Assessee, a nationalised bank

M/S. SYNDICATE BANK,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), RANGE- 3, BANGALORE

In the result, all the appeals by the assessees are allowed

Bench: Shri N.V. Vasudevan & Shri B.R.Baskaran

112, J C Road, Bangalore. Bangalore – 560 002. TAN : BLRS 14425F PAN: AAACC 6106G Appellant by : Mr. S. Ananthan & Ms. Lalitha Rameswaran, CAs Respondent by : Ms. R. Premi, JCIT SR.DR(ITAT), Bengaluru. Date of hearing : 01.10.2020 Date of Pronouncement : 05.10.2020 O R D E R Per N.V. Vasudevan, Vice President These are all appeals by the Assessee, a nationalised bank

M/S PRAXAIR INDIA PRIVATE LIMITED ,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2 , BANGALORE

In the result, both the appeals of the assessee in IT(TP)A No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalty proceedings under section 271(1)(c) of the Act for furnishing inaccurate particulars of income. IT(TP)A No.3336/Bang/2018 & IT(TP)A No.199/Bang/2021 M/s. Praxier India Pvt. Ltd., Bengaluru Page 14 of 62 4. Ground Nos.1 to 4 in the AY 2014-15 and ground Nos.1 & 2 in the AY 2015-16 are general in nature, which

M/S. PRAXAIR INDIA PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, both the appeals of the assessee in IT(TP)A No

Bench: Shri Chandra Poojari & Smt. Beena Pillai

penalty proceedings under section 271(1)(c) of the Act for furnishing inaccurate particulars of income. IT(TP)A No.3336/Bang/2018 & IT(TP)A No.199/Bang/2021 M/s. Praxier India Pvt. Ltd., Bengaluru Page 14 of 62 4. Ground Nos.1 to 4 in the AY 2014-15 and ground Nos.1 & 2 in the AY 2015-16 are general in nature, which

GOOGLE INDIA PVT. LTD. vs. DCIT, BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Section, including ` IT(TP)A No.68 & 205/Bang/2015 IT(TP)A No.559 & 881/Bang/2016 IT(TP)A 387 & 2890/Bang/2017 IT(TP)A 3430/Bang/2018 IT(TP)A 2301/Bang/2019 Page 48 of 126 the existence of any arbitral proceedings, information disclosed in the course of such arbitral proceedings, and any settlements, negotiations, discussions, proposals, and awards related thereto shall be considered confidential information

M/S. GOOGLE INDIA PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(2), BANGALORE

In the result, the appeals filed by assessee for the years under consideration are disposed of as under:

Bench: Shri Chandra Poojari & Smt. Beena Pillai

Section, including ` IT(TP)A No.68 & 205/Bang/2015 IT(TP)A No.559 & 881/Bang/2016 IT(TP)A 387 & 2890/Bang/2017 IT(TP)A 3430/Bang/2018 IT(TP)A 2301/Bang/2019 Page 48 of 126 the existence of any arbitral proceedings, information disclosed in the course of such arbitral proceedings, and any settlements, negotiations, discussions, proposals, and awards related thereto shall be considered confidential information