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

41 of 56 Category E: 270A case where original return under section 139(1) of the Act has not been filed and receipts were offered to tax in the return filed under section 148 of the Act Observation of the CIT(A) Rebuttal to the CIT(A)’s observations - The CIT(A) has rejected the submission of While the assessment

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

41 of 56 Category E: 270A case where original return under section 139(1) of the Act has not been filed and receipts were offered to tax in the return filed under section 148 of the Act Observation of the CIT(A) Rebuttal to the CIT(A)’s observations - The CIT(A) has rejected the submission of While the assessment

SRI DEEPAK S HIREMATH ,HUBBALLI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), HUBBALLI

In the result, the assessee’s appeals for Assessment Years 2008-09 to 2012-13 are allowed

Bench: Shri N. V. Vasudevan & Shri Jason P. Boaz

41,737/- under section 271(1)(c) of the Act. 2.2 For Assessment Year 2009-10, the assessee filed his return of income on 29.09.2009 declaring income of Rs.4,18,080/-. Pursuant to the iussue of notice issued under section 153A of the Act dated 18.10.2013; consequent to the search action conducted on 01.05.2013, in the case on hand

SRI DEEPAK S HIREMATH, HUBBALI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), HUBBALI

In the result, the assessee’s appeals for Assessment Years 2008-09 to 2012-13 are allowed

Bench: Shri N. V. Vasudevan & Shri Jason P. Boaz

41,737/- under section 271(1)(c) of the Act. 2.2 For Assessment Year 2009-10, the assessee filed his return of income on 29.09.2009 declaring income of Rs.4,18,080/-. Pursuant to the iussue of notice issued under section 153A of the Act dated 18.10.2013; consequent to the search action conducted on 01.05.2013, in the case on hand

SRI DEEPAK S HIREMATH, HUBBALI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), HUBBALI

In the result, the assessee’s appeals for Assessment Years 2008-09 to 2012-13 are allowed

Bench: Shri N. V. Vasudevan & Shri Jason P. Boaz

41,737/- under section 271(1)(c) of the Act. 2.2 For Assessment Year 2009-10, the assessee filed his return of income on 29.09.2009 declaring income of Rs.4,18,080/-. Pursuant to the iussue of notice issued under section 153A of the Act dated 18.10.2013; consequent to the search action conducted on 01.05.2013, in the case on hand

SRI DEEPAK S HIREMATH ,HUBBALI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), HUBBLI

In the result, the assessee’s appeals for Assessment Years 2008-09 to 2012-13 are allowed

Bench: Shri N. V. Vasudevan & Shri Jason P. Boaz

41,737/- under section 271(1)(c) of the Act. 2.2 For Assessment Year 2009-10, the assessee filed his return of income on 29.09.2009 declaring income of Rs.4,18,080/-. Pursuant to the iussue of notice issued under section 153A of the Act dated 18.10.2013; consequent to the search action conducted on 01.05.2013, in the case on hand

SRI DEEPAK S HIREMATH ,HUBALI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), HUBLI

In the result, the assessee’s appeals for Assessment Years 2008-09 to 2012-13 are allowed

Bench: Shri N. V. Vasudevan & Shri Jason P. Boaz

41,737/- under section 271(1)(c) of the Act. 2.2 For Assessment Year 2009-10, the assessee filed his return of income on 29.09.2009 declaring income of Rs.4,18,080/-. Pursuant to the iussue of notice issued under section 153A of the Act dated 18.10.2013; consequent to the search action conducted on 01.05.2013, in the case on hand

K RAMASWAMY ,MYSORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-2(1), MYSORE

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

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

41 taxmann.com 496 (Kar). In this decision, on identical facts, the Hon’ble High Court of Karnataka took a view that there is no recording of proper satisfaction, if in the assessment order the observations are only for initiating penalty proceedings u/s. 271(1)(c) of the Act. The Hon’ble High Court also considered the effect of provisions

SHRI. K. RAMASWAMY,MYSORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE--2(1),, MYSORE

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

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

41 taxmann.com 496 (Kar). In this decision, on identical facts, the Hon’ble High Court of Karnataka took a view that there is no recording of proper satisfaction, if in the assessment order the observations are only for initiating penalty proceedings u/s. 271(1)(c) of the Act. The Hon’ble High Court also considered the effect of provisions

K.RAMASWAMY ,MYSORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), MYSORE

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

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

41 taxmann.com 496 (Kar). In this decision, on identical facts, the Hon’ble High Court of Karnataka took a view that there is no recording of proper satisfaction, if in the assessment order the observations are only for initiating penalty proceedings u/s. 271(1)(c) of the Act. The Hon’ble High Court also considered the effect of provisions

SHRI. K. RAMASWAMY,MYSORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1),, MYSORE

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

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

41 taxmann.com 496 (Kar). In this decision, on identical facts, the Hon’ble High Court of Karnataka took a view that there is no recording of proper satisfaction, if in the assessment order the observations are only for initiating penalty proceedings u/s. 271(1)(c) of the Act. The Hon’ble High Court also considered the effect of provisions

SHRI. AJITH R,,MYSORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1),, MYSORE

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

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

41 taxmann.com 496 (Kar). In this decision, on identical facts, the Hon’ble High Court of Karnataka took a view that there is no recording of proper satisfaction, if in the assessment order the observations are only for initiating penalty proceedings u/s. 271(1)(c) of the Act. The Hon’ble High Court also considered the effect of provisions

SHRI. K. RAMASWAMY,,MYSORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1),, MYSORE

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

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

41 taxmann.com 496 (Kar). In this decision, on identical facts, the Hon’ble High Court of Karnataka took a view that there is no recording of proper satisfaction, if in the assessment order the observations are only for initiating penalty proceedings u/s. 271(1)(c) of the Act. The Hon’ble High Court also considered the effect of provisions

SHRI. AJITH R,MYSORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1),, MYSORE

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

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

41 taxmann.com 496 (Kar). In this decision, on identical facts, the Hon’ble High Court of Karnataka took a view that there is no recording of proper satisfaction, if in the assessment order the observations are only for initiating penalty proceedings u/s. 271(1)(c) of the Act. The Hon’ble High Court also considered the effect of provisions

R.AJITH ,MYSORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), MYSORE

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

Bench: Shri N.V. Vasudevan & Shri A.K.Garodia

41 taxmann.com 496 (Kar). In this decision, on identical facts, the Hon’ble High Court of Karnataka took a view that there is no recording of proper satisfaction, if in the assessment order the observations are only for initiating penalty proceedings u/s. 271(1)(c) of the Act. The Hon’ble High Court also considered the effect of provisions

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