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

27 of 56 Observation of the CIT(A) Rebuttal to the CIT(A)’s observations - - Assessee did not offer the FTS receipts In addition to the above, legal to tax under section 139 of the Act submissions, it is submitted that IBM - Receipts were offered to tax only after India has reported such receipts in 3CEB - proceedings under section

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

27 of 56 Observation of the CIT(A) Rebuttal to the CIT(A)’s observations - - Assessee did not offer the FTS receipts In addition to the above, legal to tax under section 139 of the Act submissions, it is submitted that IBM - Receipts were offered to tax only after India has reported such receipts in 3CEB - proceedings under section

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

27 of 56 Observation of the CIT(A) Rebuttal to the CIT(A)’s observations - - Assessee did not offer the FTS receipts In addition to the above, legal to tax under section 139 of the Act submissions, it is submitted that IBM - Receipts were offered to tax only after India has reported such receipts in 3CEB - proceedings under section

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

The appeals of the assessees are allowed

u/s 271(1)(c) ofIT Act\nand disputed in the present appeals before us are hereby cancelled.\"\n(Emphasis Supplied)\nCIT vs Harsh International Pvt Ltd (ITA 620/2019, 622/2019 and CM\nAppl 30811/2019, 301813/2019)\n“Having heard the learned counsel for the appellant and having perused the\nimpugned order, this Court is of the view that the ITAT was right

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

27 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\nAssessee did not offer the FTS receipts\nto tax under section 139 of the Act\nReceipts were offered to tax only after\nproceedings under section 201 of the\nAct

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

27 of 56\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\nAssessee did not offer the FTS receipts\nto tax under section 139 of the Act\nReceipts were offered to tax only after\nproceedings under section 201 of the\nAct were initiated in case of IBM India\nReceipts were offered to tax only after\na notice

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

27 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\n\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\n\nAssessee did not offer the FTS receipts\nto tax under section 139 of the Act\nReceipts were offered to tax only after\nproceedings under section

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

27 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\nAssessee did not offer the FTS receipts\nto tax under section 139 of the Act\nReceipts were offered to tax only after\nproceedings under section 201 of the\nAct

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

The appeals of the assessees are allowed

27 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\nAssessee did not offer the FTS receipts\nto tax under section 139 of the Act\nReceipts were offered to tax only after\nproceedings under section 201 of the\nAct

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

27 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\nAssessee did not offer the FTS receipts\nto tax under section 139 of the Act\nIn addition to the above, legal\nsubmissions, it is submitted that IBM\nIndia

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

27 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\nAssessee did not offer the FTS receipts\nto tax under section 139 of the Act\nReceipts were offered to tax only after\nproceedings under section 201 of the\nAct

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

27 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\nAssessee did not offer the FTS receipts\nto tax under section 139 of the Act\nReceipts were offered to tax only after\nproceedings under section 201 of the\nAct

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

u/s 271(1)(c) ofIT Act\nand disputed in the present appeals before us are hereby cancelled.”\n(Emphasis Supplied)\nCIT vs Harsh International Pvt Ltd (ITA 620/2019, 622/2019 and CM\nAppl 30811/2019, 301813/2019)\n“Having heard the learned counsel for the appellant and having perused the\nimpugned order, this Court is of the view that the ITAT was right

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

27 of 56\n\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\n\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\nAssessee did not offer the FTS receipts\nto tax under section 139 of the Act\nReceipts were offered to tax only after\nproceedings under section

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

27 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\nAssessee did not offer the FTS receipts\nto tax under section 139 of the Act\nReceipts were offered to tax only after\nproceedings under section 201 of the\nAct

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

27 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\nAssessee did not offer the FTS receipts\nto tax under section 139 of the Act\nReceipts were offered to tax only after\nproceedings under section 201 of the\nAct

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

27 of 56\n\nObservation of the CIT(A)\n\n- Assessee did not offer the FTS receipts\nto tax under section 139 of the Act\n- Receipts were offered to tax only after\nproceedings under section 201 of the\nAct were initiated in case of IBM India\n- Receipts were offered to tax only after\na notice under section

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

27 of 56\n\nObservation of the CIT(A)\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\n\nRebuttal to the CIT(A)'s observations\n\nAssessee did not offer the FTS receipts\nto tax under section 139 of the Act\nReceipts were offered to tax only after\nproceedings under section