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

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 9 of 56 Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

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

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 9 of 56 Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

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

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 9 of 56 Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

SIMPLEX TMC PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(1),BENGALURU, BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2018-19

25,35,000/- and the remaining amount of Rs.3,94,65,600/- was received by way of cheque. Further, he stated that out of this sale consideration received in cash, Rs. 4 Crore was kept in the locker held in Karur Vysya Bank, Koramangala Branch and the remaining cash was utilised for various expenses. The same has been reiterated

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 Page 9 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

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

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 Page 9 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

25-04-2024 and was identified with acute pancreatic problem and since then I can say that my health condition further deteriorated and finding it difficult to cope up. 9. I sate that, I am not verifying mail personally as I am not knowing computer and due to poor eye sight. I also state that I am not verifying Income

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

u/s 271AAB of the I.T Act, 1961. 24. Thus, we notice that both the tax authorities are not clear about the charge for which the penalty was imposed. An identical issue was considered by the Chennai bench of Tribunal in the case of R. Elangovan (supra), wherein the Tribunal has observed as under:- “…. It is clear from the sub-section

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

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 Page 9 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 Page 9 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

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

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 Page 9 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 Page 9 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

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

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 Page 9 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

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

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 Page 9 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE vs. SANTOSH SHIVAJI LAD, BANGALORE

In the result, the appeal of the Revenue is hereby dismissed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2013-14

25, 2023, requiring the assessee . Page 6 of 16 to appear personally the very next day. Subsequently, the AO passed the penalty order on April 28, 2023. Thus, the reasonable opportunity of being heard, as mandated under the law was not provided, rendering the penalty order invalid. 9.1 Furthermore, the assessee submitted that any addition or disallowance made

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

271(1)(c) 497/Bang/2024 | Filed but In ROI filed Limited 17 not offered u/s 148 Page 9 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

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

25,621. In this assessment period, the assessee sold agricultural land and declared Long Term Capital Gains (LTCG) thereon; apart from declaring income / loss from other heads such as house property, business and other sources. The assessment was completed under section 143(3) of the Act by order dt.15.12.2008 wherein the income of the assessee was determined at Rs.5

R G PATIL & COMPANY,HAVERI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE, BELAGAVI

In the result, these 2 appeals of the assessee in ITA Nos

Bench: Shri George George K & Shri Laxmi Prasad Sahu

u/s. 271(1)(c) amounting to Rs.3,090/-, Rs1,29,780 and Rs.2,62,650/- for assessment years 2010-11, 2011- 12 and 2013-14 respectively is upheld. Consequently. ground no. 3 and 4 are dismissed. 6. Ground no.5 is relating to the fact that the declaration of undisclosed income made by the appellant during the course of search