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
ITA 544/BANG/2024[2017-18]Status: DisposedITAT Bangalore20 May 2024AY 2017-18
Bench: Shri Chandra Poojari & Smt. Beena Pillai
197 of the Act in order to understand its tax liability.
4.2
Specific observation by the AO with respect to penalty under section 271(1)(c) of the Act
4.2.1 The AO in the penalty order has confirmed that the Assessee has ‘concealed’ particulars of income under section 271