RAGHURAM ENTERPRISES,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

271(1)(c) of the Act. Hence, the ground of appeal of the assessee is allowed. 14. In the result, the appeal of the assessee is allowed. . ITA No.1835 to 1840/Bang/2025 Page 9 of 18 Coming to ITA/1836/Bang/2025 AY 2014-15, ITA/1837/Bang/2025 AY 2015-16, ITA/1838/Bang/2025 AY 2016-17. 15. At the outset, we note that the issues raised

RAGHURAM ENTERPRISES ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

271(1)(c) of the Act. Hence, the ground of appeal of the assessee is allowed. 14. In the result, the appeal of the assessee is allowed. . ITA No.1835 to 1840/Bang/2025 Page 9 of 18 Coming to ITA/1836/Bang/2025 AY 2014-15, ITA/1837/Bang/2025 AY 2015-16, ITA/1838/Bang/2025 AY 2016-17. 15. At the outset, we note that the issues raised

RAGHURAM ENTERPRISES,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3),, BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

271(1)(c) of the Act. Hence, the ground of appeal of the assessee is allowed. 14. In the result, the appeal of the assessee is allowed. . ITA No.1835 to 1840/Bang/2025 Page 9 of 18 Coming to ITA/1836/Bang/2025 AY 2014-15, ITA/1837/Bang/2025 AY 2015-16, ITA/1838/Bang/2025 AY 2016-17. 15. At the outset, we note that the issues raised

RAGHURAM ENTERPRISES,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

271(1)(c) of the Act. Hence, the ground of appeal of the assessee is allowed. 14. In the result, the appeal of the assessee is allowed. . ITA No.1835 to 1840/Bang/2025 Page 9 of 18 Coming to ITA/1836/Bang/2025 AY 2014-15, ITA/1837/Bang/2025 AY 2015-16, ITA/1838/Bang/2025 AY 2016-17. 15. At the outset, we note that the issues raised

RAGHURAM ENTERPRISES,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

271(1)(c) of the Act. Hence, the ground of appeal of the assessee is allowed. 14. In the result, the appeal of the assessee is allowed. . ITA No.1835 to 1840/Bang/2025 Page 9 of 18 Coming to ITA/1836/Bang/2025 AY 2014-15, ITA/1837/Bang/2025 AY 2015-16, ITA/1838/Bang/2025 AY 2016-17. 15. At the outset, we note that the issues raised

M/S. CONCORDE HOUSING CORPORATION PRIVATE LIMITED,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(4), BENGALURU

In the result, appeal of the assessee in ITA No

Bench: Shri Chandra Poojari & Shri Prakash Chand Yadav

Section 271(1)(c) the Appellant was subjected to the proceedings in the show cause notice, when there are 6 Explanations are provided u/s 271(1)(c) of the Act. 11. The Ld. AO erred in the penalty order by ignoring the jurisprudence laid by various Courts and CBDT Circulars. 12. The Appellant submits that each of the above grounds

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

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

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

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

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

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

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

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

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

u/s 27l(l)(c) ofIT Act and disputed in the present appeals before us are hereby cancelled." (Emphasis Supplied) CIT vs Harsh International Pvt Ltd (ITA 620/2019, 622/2019 and CM Appl 30811/2019, 301813/2019) “Having heard the learned counsel for the appellant and having perused the impugned order, this Court is of the view that the ITAT was right in deleting

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

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