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 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) 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 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) 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

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) 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

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) 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

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) 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

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) 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

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) 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

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) 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

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) 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

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) 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

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

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

SMT. ROOPA SURYANARAYANA,BANGALORE vs. ITO, BANGALORE

In the result, the appeals are allowed

Bench: Smt. Asha Vijayaraghavan & Shri Inturi Rama Raoita Nos. 997 To 1001/Bang/2014 (Asst. Years : 2004-05 To 2008-09) Smt. Roopa Suryanarayana, Prop. Yashasvi Packs, No.44, 4Th Cross, Ad Halli, Magadi Main Road, Bangalore-560 040. . Appellant Pan: Admpr 9875K

251 ITR 99 (SC); f) Bharat Rice Mill Vs. CIT (2005) 278 ITR 299 (All). 8. At the time of appeal hearing before the CIT(A) the appellant reiterated that in the present case, difference in income returned in the original and revised return was made voluntarily with full co-operation with the Department. The difference of income returned

M/S TEXAS INSTRUMENTS (INDIA ) PRIVATE LIMITED,BANGALORE vs. ADDLCIT, BANGALORE

In the result, both the assessee’s as well as Revenue’s appeals are treated as partly allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri Jason P Boazjoint Commissioner Of Income-Tax (Ltu), Bangalore. … Appellant Vs. M/S.Texas Instruments, Bagmane Tech Park, No.66/3 Adjacent To Lrde, Byrasandra, C V Raman Nagar Post Bangalore-560093. … Respondent Pan: Aaact5445M

penalty under section 271. Section 251 of the Act deals with the powers of the CIT(A) in disposing of the appeals filed before him/her. Thus, it is clear, that where the CIT(A) had called for details on such direction and the assessee files such details on such direction, it is not incumbent upon the CIT(A) to call

JCIT, BANGALORE vs. M/S TEXAS INSTRUMENTS, BANGALORE

In the result, both the assessee’s as well as Revenue’s appeals are treated as partly allowed for statistical purposes

Bench: Smt. P. Madhavi Devi & Shri Jason P Boazjoint Commissioner Of Income-Tax (Ltu), Bangalore. … Appellant Vs. M/S.Texas Instruments, Bagmane Tech Park, No.66/3 Adjacent To Lrde, Byrasandra, C V Raman Nagar Post Bangalore-560093. … Respondent Pan: Aaact5445M

penalty under section 271. Section 251 of the Act deals with the powers of the CIT(A) in disposing of the appeals filed before him/her. Thus, it is clear, that where the CIT(A) had called for details on such direction and the assessee files such details on such direction, it is not incumbent upon the CIT(A) to call

SRI. VENKATESWARA DEVELOPERS,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 7(2)(1), BENGALURU

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri George George K.

251(2) of the Income Tax Act, 1961.” 2. The assessee raised following grounds of appeal in ITA No.2474/Bang/2019 as follows:- Ground No.1 • The Commissioner of Income tax (Appeals)-7 has erred in imposing penalty of Rs.300 lakhs u/s 271(1)(c) of the Income Tax Act,1961 alleging that the appellant has furnished inaccurate particulars of income

SRI VENKATESWARA DEVELOPERS,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE- 7(2)(1), BANGALORE

In the result, both the appeals filed by the assessee are partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Shri George George K.

251(2) of the Income Tax Act, 1961.” 2. The assessee raised following grounds of appeal in ITA No.2474/Bang/2019 as follows:- Ground No.1 • The Commissioner of Income tax (Appeals)-7 has erred in imposing penalty of Rs.300 lakhs u/s 271(1)(c) of the Income Tax Act,1961 alleging that the appellant has furnished inaccurate particulars of income

M/S. PAUL RESORTS & HOTELS PVT LTD,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX. CENTRAL CIRCLE-1(1), BANGALORE

penalty proceedings u/s 271(1)(c) of the Act is\ninitiated separately.\n14.5 With regard to Undisclosed income from transport business\nthe ld. D.R. submitted that during the course of search, a document\nA/JDPL/12 was found and seized. It contained entries relating to\nincome earned by the assessee while returning from the various\ndepots of KSBCL. The alcohol manufactured