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

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 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

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

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

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

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

The appeals of the assessees are allowed

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

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

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

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

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

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

The appeals of the assessees are allowed

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

2)\nof the Act on 3 August 2012 in respect of ROI 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

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

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

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

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