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

u/s Receipts were not offered under section 139) and thereby contending that the 139 of the Act basis juridical precedents/ Assessee had not disclosed all the facts IBM Corp’s order for AY 2011-12. - material to the computation of its total AO cannot contend that the Assessee had income. Reference drawn to Delhi not disclosed all material facts, especially

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

u/s Receipts were not offered under section 139) and thereby contending that the 139 of the Act basis juridical precedents/ Assessee had not disclosed all the facts IBM Corp’s order for AY 2011-12. - material to the computation of its total AO cannot contend that the Assessee had income. Reference drawn to Delhi not disclosed all material facts, especially

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

u/s Receipts were not offered under section 139) and thereby contending that the 139 of the Act basis juridical precedents/ Assessee had not disclosed all the facts IBM Corp’s order for AY 2011-12. - material to the computation of its total AO cannot contend that the Assessee had income. Reference drawn to Delhi not disclosed all material facts, especially

M/S STUMP SCHUELE AND SOMAPPA SPRINGS PRIVATE LIMITED ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX LTU CIRCLE-1 , BANGALORE

In the result, the assessee’s appeal for Assessment Year 2012-13

Bench: Shri Jason P. Boaz & Shri Pavan Kumar Gadaleassessment Year : 2012-13 M/S. Stumpp Schuele & Vs. The Deputy Commissioner Of Somappa Springs Pvt. Ltd., Income Tax, Ltu, No.139/2, Hosur Road, Circle - 1, Koramangala, Bengaluru. Bengaluru-560 095. Pan : Aalcs 7347 E Appellant Respondent Assessee By : Smt. Sowmya, Advocate Revenue By : Shri. M. Rajasekhar, Addl. Cit Date Of Hearing : 14.03.2019 Date Of Pronouncement : 15.03.2019 O R D E R Per Jason P. Boazthis Appeal By The Assessee Is Directed Against The Order Of Cit(A)-10, Bangalore, Dated 01.02.2018 For Assessment Year 2012-13, Upholding The Levy Of Penalty Under Section 271(1)(C) Of The Income Tax Act, 1961 (In Short ‘The Act’) For Assessment Year 2012-13. 2. Briefly Stated, The Facts Relevant For Disposal Of This Appeal Are As Under: Page 2 Of 9 2.1 The Assessee, A Company Engaged In The Manufacture & Supply Of Stabilizer Bars & All Varieties Of Springs, Automobile Components, Spare Parts, Accessories, Etc., Filed Its Return Of Income For Assessment Year 2012-13 On 30.09.2012 Declaring Loss Of (-) Rs.5,34,42,031/- Under Normal Provisions & ‘Book Profits’ Of Rs.2,88,52,729/- Under Section 115Jb Of The Act. The Case Was Taken Up For Assessment For This Assessment Year & The Assessment Was Concluded Under Section 143(3) Of The Act Vide Order Dated 13.03.2015, Wherein The Assessee’S Loss Was Determined At Rs.4,55,68,066/- In View Of The Following Additions / Deductions:- (I) Disallowance Of Deduction Under Section 35(2Ab) – Rs.14,34,982/- (Ii) Disallowance Of Leave Encashment – Rs.64,38,983/-.

42,031/- under normal provisions and ‘book profits’ of Rs.2,88,52,729/- under section 115JB of the Act. The case was taken up for assessment for this Assessment Year and the assessment was concluded under section 143(3) of the Act vide order dated 13.03.2015, wherein the assessee’s loss was determined at Rs.4,55,68,066/- in view

HARSHAVARDHAN ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CENTRAL CIRCLE-1(4), BANGALORE

In the result, all 13 appeals of the assessee are allowed

42,500/- in A. Y. 2009 – 10, Rs. 30,000/- in A. Y. 2010 – 11, Rs. 150,000/- in A. Y. 2011 – 12, Rs. 150,000/- in A. Y. 2012 – 13, Rs. 72,225/- in A. Y. 2013 – 14 and 82,550/- in A. Y. 2014 – 15. 3. It was submitted by the learned AR of the assessee that

SRI RAMAIAH REDDY ,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-4(2)(1), BANGALORE

In the result, assessee’s appeal for asst

Bench: Shri Vijaypal Rao & Shri Jason P Boazsri C Ramaiah Reddy, Ramaiah Reddy Colony, Sector ‘C’, Basavanagar, Marthahalli, Bengaluru. . Appellant Vs.

42,43,772/- as against revised declared income of Rs.23,97,25,547/- due to various additions made therein, In the order of assessment the Assessing Officer (‘AO’) observed that the assessee had only declared the sum of Rs.50 lakhs on account of unexplained jewellery as per the declaration u/s 132(4) of the Act in the return of income

RAGHURAM ENTERPRISES,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3),, BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

section 271(1)(c) of the Act. Hence, the ground of appeal of the assessee is allowed. 14. In the result, the appeal of the assessee is allowed. . ITA No.1835 to 1840/Bang/2025 Page 9 of 18 Coming to ITA/1836/Bang/2025 AY 2014-15, ITA/1837/Bang/2025 AY 2015-16, ITA/1838/Bang/2025 AY 2016-17. 15. At the outset, we note that the issues raised

RAGHURAM ENTERPRISES ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

section 271(1)(c) of the Act. Hence, the ground of appeal of the assessee is allowed. 14. In the result, the appeal of the assessee is allowed. . ITA No.1835 to 1840/Bang/2025 Page 9 of 18 Coming to ITA/1836/Bang/2025 AY 2014-15, ITA/1837/Bang/2025 AY 2015-16, ITA/1838/Bang/2025 AY 2016-17. 15. At the outset, we note that the issues raised

RAGHURAM ENTERPRISES,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

section 271(1)(c) of the Act. Hence, the ground of appeal of the assessee is allowed. 14. In the result, the appeal of the assessee is allowed. . ITA No.1835 to 1840/Bang/2025 Page 9 of 18 Coming to ITA/1836/Bang/2025 AY 2014-15, ITA/1837/Bang/2025 AY 2015-16, ITA/1838/Bang/2025 AY 2016-17. 15. At the outset, we note that the issues raised

RAGHURAM ENTERPRISES,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

section 271(1)(c) of the Act. Hence, the ground of appeal of the assessee is allowed. 14. In the result, the appeal of the assessee is allowed. . ITA No.1835 to 1840/Bang/2025 Page 9 of 18 Coming to ITA/1836/Bang/2025 AY 2014-15, ITA/1837/Bang/2025 AY 2015-16, ITA/1838/Bang/2025 AY 2016-17. 15. At the outset, we note that the issues raised

RAGHURAM ENTERPRISES,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

section 271(1)(c) of the Act. Hence, the ground of appeal of the assessee is allowed. 14. In the result, the appeal of the assessee is allowed. . ITA No.1835 to 1840/Bang/2025 Page 9 of 18 Coming to ITA/1836/Bang/2025 AY 2014-15, ITA/1837/Bang/2025 AY 2015-16, ITA/1838/Bang/2025 AY 2016-17. 15. At the outset, we note that the issues raised

RAGHURAM ENTERPRISES ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(3), BANGALORE

In the result, the appeal of the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

section 271(1)(c) of the Act. Hence, the ground of appeal of the assessee is allowed. 14. In the result, the appeal of the assessee is allowed. . ITA No.1835 to 1840/Bang/2025 Page 9 of 18 Coming to ITA/1836/Bang/2025 AY 2014-15, ITA/1837/Bang/2025 AY 2015-16, ITA/1838/Bang/2025 AY 2016-17. 15. At the outset, we note that the issues raised

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALORE vs. INCOME TAX OFFICER, WARD-1(1), MANGALORE

In the result, all these 9 appeals filed by the assessee are allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

section 11 & 12 of the Act. Further penalty proceedings were also initiated u/s. 271(1)(c) of the Act for concealment of income. 4. During the penalty proceedings the assessee made submission. 5. The ld. AO noted that assessee is a society registered under the Karnataka Societies Registration Act, 1960, which is mainly engaged in undertaking civil contract work

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALORE vs. INCOME TAX OFFICER, WARD-1(1), MANGALORE

In the result, all these 9 appeals filed by the assessee are allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

section 11 & 12 of the Act. Further penalty proceedings were also initiated u/s. 271(1)(c) of the Act for concealment of income. 4. During the penalty proceedings the assessee made submission. 5. The ld. AO noted that assessee is a society registered under the Karnataka Societies Registration Act, 1960, which is mainly engaged in undertaking civil contract work

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALORE vs. INCOME TAX OFFICER, WARD-1(1), MANGALORE

In the result, all these 9 appeals filed by the assessee are allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

section 11 & 12 of the Act. Further penalty proceedings were also initiated u/s. 271(1)(c) of the Act for concealment of income. 4. During the penalty proceedings the assessee made submission. 5. The ld. AO noted that assessee is a society registered under the Karnataka Societies Registration Act, 1960, which is mainly engaged in undertaking civil contract work

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALORE vs. INCOME TAX OFFICER, WARD-1(1), MANGALORE

In the result, all these 9 appeals filed by the assessee are allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

section 11 & 12 of the Act. Further penalty proceedings were also initiated u/s. 271(1)(c) of the Act for concealment of income. 4. During the penalty proceedings the assessee made submission. 5. The ld. AO noted that assessee is a society registered under the Karnataka Societies Registration Act, 1960, which is mainly engaged in undertaking civil contract work

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALORE vs. INCOME TAX OFFICER, WARD-1(1), MANGALORE

In the result, all these 9 appeals filed by the assessee are allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

section 11 & 12 of the Act. Further penalty proceedings were also initiated u/s. 271(1)(c) of the Act for concealment of income. 4. During the penalty proceedings the assessee made submission. 5. The ld. AO noted that assessee is a society registered under the Karnataka Societies Registration Act, 1960, which is mainly engaged in undertaking civil contract work

DAKSHINA KANNADA NIRMITHI KENDRA ,MANGALORE vs. INCOME TAX OFFICER, WARD-1(1), MANGALORE

In the result, all these 9 appeals filed by the assessee are allowed

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

section 11 & 12 of the Act. Further penalty proceedings were also initiated u/s. 271(1)(c) of the Act for concealment of income. 4. During the penalty proceedings the assessee made submission. 5. The ld. AO noted that assessee is a society registered under the Karnataka Societies Registration Act, 1960, which is mainly engaged in undertaking civil contract work