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

273B of the Act. - The reference to the above case by the Assessee was only in the context of the legal principle emanating from the same which could also be used in the context of section 271(1)(c) of the Act. - However, the CIT(A) has incorrectly opined that the reference to the subject ruling is misplaced merely because

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

273B of the Act. - The reference to the above case by the Assessee was only in the context of the legal principle emanating from the same which could also be used in the context of section 271(1)(c) of the Act. - However, the CIT(A) has incorrectly opined that the reference to the subject ruling is misplaced merely because

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

273B of the Act. - The reference to the above case by the Assessee was only in the context of the legal principle emanating from the same which could also be used in the context of section 271(1)(c) of the Act. - However, the CIT(A) has incorrectly opined that the reference to the subject ruling is misplaced merely because

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

273B of the Act. - The reference to the above case by the Assessee was only in the context of the legal principle emanating from the same which could also be used in the context of section 271(1)(c) of the Act. - However, the CIT(A) has incorrectly opined that the reference to the subject ruling is misplaced merely because

BHADRAVATHI RAMALINGASETTY MANJUNATH SETTY,BHADRAVATHI vs. ITO WARD-1 TPS , SHIMOGA

In the result, appeal filed by the assessee is allowed

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2018-19

271-G' by Finance Act, 2015 (No. 20 of 2015), dated 14.5.2015.][, clause (c) or clause (d) of sub-section (1) or sub-section (2) of section 272-A, sub-section (1) of section 272-AA or ] [Inserted by Act 46 of 1986, Section 26 (w.e.f. 10.9.1986).][section 272-B or] [ Inserted by Act 20 of 2002, Section 106 (w.e.f

GOPAL KRISHNA KARODI SABBANA,DAKSHINA KANNADA vs. DY./ASST.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, MANGALORE

In the result, appeals filed by the assessee for all these AY are allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

u/s. 271B of the Act were levied by the AO for all these AYs under consideration. Before AO, the assessee submitted his reply stating that the major reason for delay in filing the audit reports was due to the fact that he was suffering from blood pressure & Diabetes & frequently admitted to the hospital. Further, he also submitted that his auditor

GOPAL KRISHNA KARODI SABBANA,DAKSHINA KANNADA vs. DY./ASST.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2,, MANGALORE

In the result, appeals filed by the assessee for all these AY are allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

u/s. 271B of the Act were levied by the AO for all these AYs under consideration. Before AO, the assessee submitted his reply stating that the major reason for delay in filing the audit reports was due to the fact that he was suffering from blood pressure & Diabetes & frequently admitted to the hospital. Further, he also submitted that his auditor

GOPAL KRISHNA KARODI SABBANA ,DAKSHINA KANNADA vs. DY./ASST.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, MANGALORE

In the result, appeals filed by the assessee for all these AY are allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

u/s. 271B of the Act were levied by the AO for all these AYs under consideration. Before AO, the assessee submitted his reply stating that the major reason for delay in filing the audit reports was due to the fact that he was suffering from blood pressure & Diabetes & frequently admitted to the hospital. Further, he also submitted that his auditor

GOPAL KRISHNA KARODI SABBANA,DAKSHINA KANNADA vs. DY./ASST.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, MANGALORE

In the result, appeals filed by the assessee for all these AY are allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

u/s. 271B of the Act were levied by the AO for all these AYs under consideration. Before AO, the assessee submitted his reply stating that the major reason for delay in filing the audit reports was due to the fact that he was suffering from blood pressure & Diabetes & frequently admitted to the hospital. Further, he also submitted that his auditor

SRI. CHINNAYELLAPPA CHANDRASHEKAR, ,BANGALORE vs. INCOME TAX OFFICER, WARD-4(2)(4), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2017-18

271-G' by Finance Act, 2015 (No. 20 of 2015), dated 14.5.2015.][, clause (c) or clause (d) of sub-section (1) or sub-section (2) of section 272-A, sub-section (1) of section 272-AA or ] [Inserted by Act 46 of 1986, Section 26 (w.e.f. 10.9.1986).][section 272-B or] [ Inserted by Act 20 of 2002, Section 106 (w.e.f

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 in respect of the income being surrendered. The only argument made by the Assessee was that it voluntarily offered receipts to tax and therefore, penalty cannot be levied. Page 28 of 56 Observation of the CIT(A) - The CIT(A) has contended that the explanations offered by IBM are not bonafide, since: - The explanation

GOPAL KRISHNA KARODI SABBANA,DAKSHINA KANNADA vs. DY./ASST.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, MANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

u/s. 271B of the Act were levied by the AO for all these AYs under consideration. Before AO, the assessee submitted his reply stating that the major reason for delay in filing the audit reports was due to the fact that he was suffering from blood pressure & Diabetes & frequently admitted to the hospital. Further, he also submitted that his auditor

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 in respect of the income being surrendered. The only argument made by the Assessee was that it voluntarily offered receipts to tax and therefore, penalty cannot be levied. Page 28 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Observation of the CIT(A) Rebuttal

M/S HUBLI DHARWAD STOCK TRADING HOUSE ,HUBLI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1), HUBLI

In the result, the assessee's appeals for Assessment Years 1997-98,

Bench: Shri George George K & Shri Jason P Boaz

u/s 271(1)(c) of the Act require no adjudication by us at this stage. 5. In the result, assessee’s appeals for asst. year 1997-98, 2000-01 to 2002-03, 2004-05 and 2005-06 are allowed as indicated above. 6. Assessee's appeals in ITA Nos.891, 893, 895, 897, 899 and 902/Bang/2017. 6.1 These are six appeals

JICE ACADEMY FOR EXCELLENCE PRIVATE LIMITED,BANGALORE vs. INCOME TAX OFFICER, NFAC, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariassessment Year: 2017-18

271 D of the I.T. Act 1961. Accordingly, the Addl.CIT invoked the provisions of section 271D and levied penalty at Rs.15,64,50,000 for accepting loan in cash in violation of provisions of section 269SS as per section 271D of the Act. 19. The main contention of the ld. AR is that the transaction is genuine

MAHESHWARAPPA MUNIRAMU,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, RANGE 2(2), BENGALURU, BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year : 2017-18 Maheshwarappa Muniramu #4261/17, 2Nd Cross, 20Th Main Subramanya Nagar Jcit Vs. Bengaluru 560 021 Range 2(2) Bangalore Pan No :Aempm8290C Appellant Respondent Appellant By : Sri Nagaraj K. H., Ca Respondent By : Sri Subramaniam, Jcit Dr Date Of Hearing : 30.06.2025 Date Of Pronouncement : 26.09.2025

271-I, clause (c) or clause (d) of sub- section (1) or sub-section (2) of section 272A, sub-section (1) of section 272AA, or section 272B or sub-section (1) or sub-section (1A) of section 272BB or clause (b) of subsection (1) of section or clause (b) or clause (c) of sub-section (2) of section

M/S SYNDICATE BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS) RANGE-3 , BANGALORE

In the result, all the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazin Ita Nos. A.Y. Appellant(S) Vs. Respondent 709/Bang/2019 2012-13 Syndicate Bank, 2011-12 Rajajinagar Main Branch, Ramamandir Road, 3Rd Block, Rajajinagar, Bangalore – 560 010. Tan : Blrs 00880 F Pan: Aaccs 4699E 710/Bang/2019 2011-12 Syndicate Bank, 735/Bang/2019 2013-14 Jayanagar Market Complex Branch, The Assistant 12Th Main Road, Commissioner Of 3Rd Block, Jayanagar, Income Tax (Tds), Bangalore-560 011. Tan : Blrs 16148 G Range 3, Pan: Aaccs 4699E Bangalore. 711/Bang/2019 2011-12 Syndicate Bank, 2013-14 Bit Branch, K.R. Road,V V Puram, Bangalore-560 004. Tan : Blrs 16186 C Pan: Aaccs 4699E 712/Bang/2019 2011-12 Syndicate Bank, Vijaya College Br., R V Road, Basavangudi Bangalore – 560 004. Tan : Blrs 15334 E Pan: Aaccs 4699E

271, section 271A, section 271AA, section 271B , section 271BA, section 271BB, section 271C, section 271CA, section 271D, section 271E, section 271F, section 271FA, section 271FB, section 271G, section 271H, clause (c) or clause (d) of sub section (1) or sub-section (2) of section 272A, sub-section (1) of section 272AA or section 272B or subsection (1) or subsection

M/S. SYNDICATE BANK,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS), RANGE - 3, BANGALORE

In the result, all the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazin Ita Nos. A.Y. Appellant(S) Vs. Respondent 709/Bang/2019 2012-13 Syndicate Bank, 2011-12 Rajajinagar Main Branch, Ramamandir Road, 3Rd Block, Rajajinagar, Bangalore – 560 010. Tan : Blrs 00880 F Pan: Aaccs 4699E 710/Bang/2019 2011-12 Syndicate Bank, 735/Bang/2019 2013-14 Jayanagar Market Complex Branch, The Assistant 12Th Main Road, Commissioner Of 3Rd Block, Jayanagar, Income Tax (Tds), Bangalore-560 011. Tan : Blrs 16148 G Range 3, Pan: Aaccs 4699E Bangalore. 711/Bang/2019 2011-12 Syndicate Bank, 2013-14 Bit Branch, K.R. Road,V V Puram, Bangalore-560 004. Tan : Blrs 16186 C Pan: Aaccs 4699E 712/Bang/2019 2011-12 Syndicate Bank, Vijaya College Br., R V Road, Basavangudi Bangalore – 560 004. Tan : Blrs 15334 E Pan: Aaccs 4699E

271, section 271A, section 271AA, section 271B , section 271BA, section 271BB, section 271C, section 271CA, section 271D, section 271E, section 271F, section 271FA, section 271FB, section 271G, section 271H, clause (c) or clause (d) of sub section (1) or sub-section (2) of section 272A, sub-section (1) of section 272AA or section 272B or subsection (1) or subsection

M/S SYNDICATE BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX (TDS) RANGE-3 , BANGALORE

In the result, all the appeals by the assessee are allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazin Ita Nos. A.Y. Appellant(S) Vs. Respondent 709/Bang/2019 2012-13 Syndicate Bank, 2011-12 Rajajinagar Main Branch, Ramamandir Road, 3Rd Block, Rajajinagar, Bangalore – 560 010. Tan : Blrs 00880 F Pan: Aaccs 4699E 710/Bang/2019 2011-12 Syndicate Bank, 735/Bang/2019 2013-14 Jayanagar Market Complex Branch, The Assistant 12Th Main Road, Commissioner Of 3Rd Block, Jayanagar, Income Tax (Tds), Bangalore-560 011. Tan : Blrs 16148 G Range 3, Pan: Aaccs 4699E Bangalore. 711/Bang/2019 2011-12 Syndicate Bank, 2013-14 Bit Branch, K.R. Road,V V Puram, Bangalore-560 004. Tan : Blrs 16186 C Pan: Aaccs 4699E 712/Bang/2019 2011-12 Syndicate Bank, Vijaya College Br., R V Road, Basavangudi Bangalore – 560 004. Tan : Blrs 15334 E Pan: Aaccs 4699E

271, section 271A, section 271AA, section 271B , section 271BA, section 271BB, section 271C, section 271CA, section 271D, section 271E, section 271F, section 271FA, section 271FB, section 271G, section 271H, clause (c) or clause (d) of sub section (1) or sub-section (2) of section 272A, sub-section (1) of section 272AA or section 272B or subsection (1) or subsection