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

section 271(1)(c).That is clearly not the intendment of the Legislature. (Emphasis Supplied)  GE packaged Power Inc vs DCIT (ITA No: 765/Del/2019) (Delhi ITAT) and others “Facts are not in dispute. It is not disputed that substantial questions of law on the quantum additions confirmed by ITAT have already been framed by Hon'ble Delhi High Court regarding

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

section 271(1)(c).That is clearly not the intendment of the Legislature. (Emphasis Supplied)  GE packaged Power Inc vs DCIT (ITA No: 765/Del/2019) (Delhi ITAT) and others “Facts are not in dispute. It is not disputed that substantial questions of law on the quantum additions confirmed by ITAT have already been framed by Hon'ble Delhi High Court regarding

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the Page 26 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others penalties levied u/s 271(1)(c) and disputed in the present

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

27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the Page 26 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others penalties levied u/s 271(1)(c) and disputed in the present

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

27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the Page 26 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others penalties levied u/s 271(1)(c) and disputed in the present

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the Page 26 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others penalties levied u/s 271(1)(c) and disputed in the present

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

27l(l)(c) of IT Act disputed in the appeals before us is covered in favour of the assessee by the aforesaid orders; and, therefore, we hold that the Page 26 of 56 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others penalties levied u/s 271(1)(c) and disputed in the present

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

271(1)(c) and disputed in the present appeals before us, are not sustainable. Accordingly, the penalties levied 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

M/S. SRI. MUTHU CINE SERVICE,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

penalty proceedings u/s, 271(1)(c) for concealment of income & 27l(1)(b) for non-compliance of statutory notices, & 271 D for violating the provisions of Section

M/S. SRI. MUTHU CINE SERVICE,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

penalty proceedings u/s, 271(1)(c) for concealment of income & 27l(1)(b) for non-compliance of statutory notices, & 271 D for violating the provisions of Section