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

4 of 1988, Section 114, for " section 270, clause (a) or Clause (b) of sub-Section (1) of section 271, section 271-A, section 271-B, sub-Section (2) of section 272-A, sub-Section (1) of section 272-AA, sub-Section (1) of section 272-B" (w.e.f. 1.4.1989).][, section 271- AA] [ Inserted by Act 14 of 2001, Section

SHRISHAILAMALLIKARJUN TRADERS,NARGUND vs. INCOME TAX OFFICER, WARD-1, GADAG

In the result, appeal filed by the assessee is allowed

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

4 of 1988, Section 114, for " section 270, clause (a) or Clause (b) of sub-Section (1) of section 271, section 271-A, section 271-B, sub-Section (2) of section 272-A, sub-Section (1) of section 272-AA, sub-Section (1) of section 272-B" (w.e.f. 1.4.1989).][, section 271- AA] [ Inserted by Act 14 of 2001, Section

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

4 of 1988, Section 114, for " section 270, clause (a) or Clause (b) of sub-Section (1) of section 271, section 271-A, section 271-B, sub-Section (2) of section 272-A, sub-Section (1) of section 272-AA, sub-Section (1) of section 272-B" (w.e.f. 1.4.1989).][, section 271- AA] [ Inserted by Act 14 of 2001, Section

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

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

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 9 of 56 Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

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

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 9 of 56 Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

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

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 9 of 56 Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

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

271(1)(c) 497/Bang/2024 Filed but In ROI filed Limited 17 not offered u/s 148 IT(IT)A Nos.487 to 504/Bang/2024 & IT(IT)A Nos.541 to 546/Bang/2024 IBM Canada Limited & Others Page 9 of 56 Entity AY Section ITA No. ITR Offered to tax Category D: 270A case where original return under section 139(1) of the Act has been

MR. SHIVAKUMAR MAHADEVAIAH ,MYSORE vs. INCOME-TAX OFFICER, WARD-2(3), MYSORE

In the result, the appeal of the revenue is dismissed

Bench: Shri Chandra Poojari (Accountant Member), Shri Keshav Dubey (Judicial Member)

Penalty u/s. 271(1)(c) initiated separately by way of issue of notice u/s. 274 for furnishing of inaccu u/s. 274 for furnishing of inaccurate particulars/concealment of rate particulars/concealment of income.” 4. Thereafter the notice 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

4 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\nIBM Corporation\nC/o IBM India Private Limited\nBangalore 560 029\nVs.\nDCIT (International Taxation)\nCircle-1(2)\nBangalore\nPAN NO : AABCI0847B\nAPPELLANT\nRESPONDENT\nIT(IT)A No.503/Bang/2024\n Assessment Years: 2017-18\nIBM Netherland B V\nC/o IBM India Private Limited

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\nallowed

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

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

4 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\nIBM Corporation\nC/o IBM India Private Limited\nBangalore 560 029\nVs.\nDCIT (International Taxation)\nCircle-1(2)\nBangalore\n\nPAN NO : AABCI0847B\nAPPELLANT\nRESPONDENT\n\nIT(IT)A No.503/Bang/2024\n Assessment Years: 2017-18\n\nIBM Netherland B V\nC/o

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

4 of 56\n\nIBM Corporation\nC/o IBM India Private Limited\nBangalore 560 029\nPAN NO : AABCI0847B\nAPPELLANT\nVs.\nDCIT (International Taxation)\nCircle-1(2)\nBangalore\nRESPONDENT\n\nIT(IT)A No.503/Bang/2024\n Assessment Years: 2017-18\n\nIBM Netherland B V\nC/o IBM India Private Limited\nBangalore 560 029\nPAN NO : AACCI2916A\nAPPELLANT\nVs.\nDCIT (International Taxation)\nCircle

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

4 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\nIBM Corporation\nC/o IBM India Private Limited\nBangalore 560 029\nPAN NO : AABCI0847B\nAPPELLANT\nDCIT (International Taxation)\nVs. Circle-1(2)\nBangalore\nRESPONDENT\nIT(IT)A No.503/Bang/2024\n Assessment Years: 2017-18\n\nIBM Netherland B V\nC/o IBM India

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

4 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\nIBM Corporation\nC/o IBM India Private Limited\nBangalore 560 029\nPAN NO : AABCI0847B\nAPPELLANT\nDCIT (International Taxation)\nVs. Circle-1(2)\nBangalore\nRESPONDENT\nIT(IT)A No.503/Bang/2024\n Assessment Years: 2017-18\nIBM Netherland B V\nC/o IBM India Private Limited