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

2 Karl Storz Endoscopy India Favourable Delhi HC 13 September (P) Limited (ITA No 13 of 2010 2008) (Delhi HC) (refer page 199 – 201 of PB) 3 Abbey Business Services Favourable Bangalore 18 July 2012 India Pvt Ltd (23 ITAT Taxmann.com 346) – later on confirmed by Karnataka High Court 4 Marks & Spencer Reliance Favourable Mumbai 4 September India Private Limited

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

2 Karl Storz Endoscopy India Favourable Delhi HC 13 September (P) Limited (ITA No 13 of 2010 2008) (Delhi HC) (refer page 199 – 201 of PB) 3 Abbey Business Services Favourable Bangalore 18 July 2012 India Pvt Ltd (23 ITAT Taxmann.com 346) – later on confirmed by Karnataka High Court 4 Marks & Spencer Reliance Favourable Mumbai 4 September India Private Limited

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

2 Karl Storz Endoscopy India (P) Limited (ITA No 13 of 2008) (Delhi HC) (refer page 199 – 201 of PB) Favourable Delhi HC 13 September 2010 3 Abbey Business Services India Pvt Ltd (23 Taxmann.com 346) – later on confirmed by Karnataka High Court Favourable Bangalore ITAT 18 July 2012 4 Marks & Spencer Reliance India Private Limited [2013] Favourable Mumbai ITAT

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

2 Karl Storz Endoscopy India (P) Limited (ITA No 13 of 2008) (Delhi HC) (refer page 199 – 201 of PB) Favourable Delhi HC 13 September 2010 3 Abbey Business Services India Pvt Ltd (23 Taxmann.com 346) – later on confirmed by Karnataka High Court Favourable Bangalore ITAT 18 July 2012 4 Marks & Spencer Reliance India Private Limited [2013] Favourable Mumbai ITAT

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

2 Karl Storz Endoscopy India (P) Limited (ITA No 13 of 2008) (Delhi HC) (refer page 199 – 201 of PB) Favourable Delhi HC 13 September 2010 3 Abbey Business Services India Pvt Ltd (23 Taxmann.com 346) – later on confirmed by Karnataka High Court Favourable Bangalore ITAT 18 July 2012 4 Marks & Spencer Reliance India Private Limited [2013] Favourable Mumbai ITAT

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

2 Karl Storz Endoscopy India (P) Limited (ITA No 13 of 2008) (Delhi HC) (refer page 199 – 201 of PB) Favourable Delhi HC 13 September 2010 3 Abbey Business Services India Pvt Ltd (23 Taxmann.com 346) – later on confirmed by Karnataka High Court Favourable Bangalore ITAT 18 July 2012 4 Marks & Spencer Reliance India Private Limited [2013] Favourable Mumbai ITAT

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

2 Karl Storz Endoscopy India (P) Limited (ITA No 13 of 2008) (Delhi HC) (refer page 199 – 201 of PB) Favourable Delhi HC 13 September 2010 3 Abbey Business Services India Pvt Ltd (23 Taxmann.com 346) – later on confirmed by Karnataka High Court Favourable Bangalore ITAT 18 July 2012 4 Marks & Spencer Reliance India Private Limited [2013] Favourable Mumbai ITAT

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

2 Karl Storz Endoscopy India (P) Limited (ITA No 13 of 2008) (Delhi HC) (refer page 199 – 201 of PB) Favourable Delhi HC 13 September 2010 3 Abbey Business Services India Pvt Ltd (23 Favourable Bangalore ITAT 18 July 2012 Taxmann.com 346) – later on confirmed by Karnataka High Court 4 Marks & Spencer Reliance India Private Limited [2013] Favourable Mumbai ITAT

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

2 Karl Storz Endoscopy India (P) Limited (ITA No 13 of 2008) (Delhi HC) (refer page 199 – 201 of PB) Favourable Delhi HC 13 September 2010 3 Abbey Business Services India Pvt Ltd (23 Taxmann.com 346) – later on confirmed by Karnataka High Court Favourable Bangalore ITAT 18 July 2012 4 Marks & Spencer Reliance India Private Limited [2013] Favourable Mumbai ITAT

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

2 3 Karl Storz Endoscopy India (P) Limited (ITA No 13 of 2008) (Delhi HC) (refer page 199 – 201 of PB) Abbey Business Services India Pvt Ltd (23 Taxmann.com 346) – later on confirmed by Karnataka High Court Favourable Delhi HC 13 September 2010 Favourable Bangalore ITAT 18 July 2012 4 Marks & Spencer Reliance India Private Limited [2013] Favourable Mumbai ITAT

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

2 Karl Storz Endoscopy India (P) Limited (ITA No 13 of 2008) (Delhi HC) (refer page 199 – 201 of PB) Favourable Delhi HC 13 September 2010 3 Abbey Business Services India Pvt Ltd (23 Taxmann.com 346) – later on confirmed by Karnataka High Court Favourable Bangalore ITAT 18 July 2012 4 Marks & Spencer Reliance India Private Limited [2013] Favourable Mumbai ITAT

INCOME TAX OFFICER, WARD-7(2)(1), BENGALURU, BANGALORE vs. M/S. BANGALORE CREDIT CO-OPERATIVE SOCIETY LIMITED , BANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

251 ITR 194) has held that interest arising from investment made, in compliance with statutory provisions to enable it to carry on banking business, out of reserve fund by a co-operative society engaged in banking business, is exempt under section 80P(2)(a)(i) of the Income-tax Act, 1961. The placement of such funds being imperative

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

2)\nof the Act on 3 August 2012 in respect of Rol filed for AY 2011-12. It\nis in the said assessment for the AY 2011-12 that the issue of\ntaxation of secondment reimbursements was first scrutinized\nthreadbare. After a thorough analysis of this issue, an amount of\nRs 83,49,00,000 was accepted

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

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

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

INCOME-TAX OFFICER, WARD-7(2)(1), BENGALURU, BENGALURU vs. M/S. BANGALORE CREDIT CO-OPERATIVE SOCIETY LIMITED, BENGALURU

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

251 ITR 194) has held that interest arising from investment made, in compliance with statutory provisions to enable it to carry on banking business, out of reserve fund by a co-operative society engaged in banking business, is exempt under section 80P(2)(a)(i) of the Income-tax Act, 1961. The placement of such funds being imperative

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

2) issued and\nassessment pending u/s 143(3)\nPending regular assessment\nproceedings would abate and would\nconverge/merge in proceedings u/s\n153A.\nAccordingly the scope of\nassessment under section 153A\nwould cover the pending return\n6. Assessment u/s 143(3)\ncompleted.\nSince regular assessment\nproceedings have been completed &\nare not pending, there would be no\nabatement of proceedings.\nAO loses jurisdiction