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

II [2013] 38\ntaxmann.com 448 (SC) to support the\nabove contention\n(Page 10/11/15/16 of the CIT(A)'s order)\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1

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

The appeals of the assessees are allowed

II [2013] 38\ntaxmann.com 448 (SC) to support the\nabove contention\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect of the income being

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

II [2013] 38\ntaxmann.com 448 (SC) to support the\nabove contention\n(Page 10/11/15/16 of the CIT(A)'s order)\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1

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

II [2013] 38\ntaxmann.com 448 (SC) to support the\nabove contention\n(Page 10/11/15/16 of the CIT(A)'s order)\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1

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

The appeals of the assessees are allowed

II [2013] 38\ntaxmann.com 448 (SC) to support the\nabove contention\n(Page 10/11/15/16 of the CIT(A)'s order)\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1

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) Data P. Ltd. vs CIT-II [2013] 38 of the Act in respect of the income being taxmann.com 448 (SC) to support the surrendered. The only argument made by above contention the Assessee was that it voluntarily offered receipts to tax and therefore, (Page 10/11/15/16 of the CIT(A)’s order) penalty cannot be levied

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

II [2013] 38\ntaxmann.com 448 (SC) to support the\nabove contention\n(Page 10/11/15/16 of the CIT(A)'s order)\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1

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

u/s\n139) and thereby contending that the\nAssessee had not disclosed all the facts\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect

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

II [2013] 38\ntaxmann.com 448 (SC) to support the\nabove contention\n(Page 10/11/15/16 of the CIT(A)'s order)\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1

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

section 271(1)(c) Data P. Ltd. vs CIT-II [2013] 38 of the Act in respect of the income being taxmann.com 448 (SC) to support the surrendered. The only argument made by above contention the Assessee was that it voluntarily offered receipts to tax and therefore, (Page 10/11/15/16 of the CIT(A)’s order) penalty cannot be levied

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

II [2013] 38\ntaxmann.com 448 (SC) to support the\nabove contention\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1)(c)\nof the Act in respect of the income being

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

II [2013] 38\ntaxmann.com 448 (SC) to support the\nabove contention\n(Page 10/11/15/16 of the CIT(A)'s order)\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1

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

II [2013] 38\ntaxmann.com 448 (SC) to support the\nabove contention\n(Page 10 of the CIT(A)'s order)\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1

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

II [2013] 38\ntaxmann.com 448 (SC) to support the\nabove contention\n(Page 10/11/15/16 of the CIT(A)'s order)\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1

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) Data P. Ltd. vs CIT-II [2013] 38 of the Act in respect of the income being taxmann.com 448 (SC) to support the surrendered. The only argument made by above contention the Assessee was that it voluntarily offered receipts to tax and therefore, (Page 10/11/15/16 of the CIT(A)’s order) penalty cannot be levied

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

II [2013] 38\ntaxmann.com 448 (SC) to support the\nabove contention\n(Page 10/11/15/16 of the CIT(A)'s order)\nMAK Data (supra) ruling is in the context\nof a case where income was voluntarily\noffered pursuant to a survey proceeding\nunder section 133A of the Act. No\nbonafide explanations were provided\nunder Explanation 1 of section 271(1

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

section 271(1)(c) Data P. Ltd. vs CIT-II [2013] 38 of the Act in respect of the income being taxmann.com 448 (SC) to support the surrendered. The only argument made by above contention the Assessee was that it voluntarily offered receipts to tax and therefore, (Page 10/11/15/16 of the CIT(A)’s order) penalty cannot be levied

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

271(1)(c) case where original return under section\n139(1) of the Act has been filed however, secondment related\nreceipts were offered to tax only in the return filed under section\n148 of the Act\n\nObservation of the CIT(A)\n\n- Assessee did not offer the FTS receipts\nto tax under section