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) of the Act (i.e, whether for concealment of income or for furnishing of inaccurate particulars) was not discernible from the penalty orders. 4.4.3 With respect to penalty levied under section 270A (AY 2017-18 to AY 2019-20) of the Act, the following specific submissions / contentions were made before the CIT(A): a) Substantiating the ‘bonafide’ intention

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

271(1)(c) of the Act (i.e, whether for concealment of income or for furnishing of inaccurate particulars) was not discernible from the penalty orders. 4.4.3 With respect to penalty levied under section 270A (AY 2017-18 to AY 2019-20) of the Act, the following specific submissions / contentions were made before the CIT(A): a) Substantiating the ‘bonafide’ intention

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

The appeals of the assessees are allowed

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide

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

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

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide

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

The appeals of the assessees are allowed

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide

IBM CHINA HONG KONG LIMITED,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

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide

IBM JAPAN 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

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide

IBM JAPAN 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

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide

IBM JAPAN 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

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n\n4.4.3\nWith respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\n\na) Substantiating

IBM OSTERREICH INTIONATIONALE BUROMASCHINEN GESELLSCHAFT MBH,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

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

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide

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

271(1)(c) of the Act (i. e,\nwhether for concealment of income or for furnishing of inaccurate\nparticulars) was not discernible from the penalty orders.\n4.4.3 With respect to penalty levied under section 270A (AY 2017-18\nto AY 2019-20) of the Act, the following specific submissions /\ncontentions were made before the CIT(A):\na) Substantiating the ‘bonafide