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 270A of the Act by NFAC arising out of different orders of NFAC for the respective above assessment years. 2. Facts of the case are that IBM is a multinational corporation, headquartered in the USA with multiple subsidiaries around the globe, including India. IBM foreign entities received notices under section 148/ section 143(2) of the Income

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

u/s 270A of the Act by NFAC arising out of different orders of NFAC for the respective above assessment years. 2. Facts of the case are that IBM is a multinational corporation, headquartered in the USA with multiple subsidiaries around the globe, including India. IBM foreign entities received notices under section 148/ section 143(2) of the Income

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 270A of the Act by NFAC arising out of different orders of NFAC for the respective above assessment years. 2. Facts of the case are that IBM is a multinational corporation, headquartered in the USA with multiple subsidiaries around the globe, including India. IBM foreign entities received notices under section 148/ section 143(2) of the Income

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

u/s 270A of the Act by NFAC arising out of different orders of NFAC for the respective above assessment years. 2. Facts of the case are that IBM is a multinational corporation, headquartered in the USA with multiple subsidiaries around the globe, including India. IBM foreign entities received notices under section 148/ section 143(2) of the Income

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

271-G' by Finance Act, 2015 (No. 20 of 2015), dated 14.5.2015.][, clause (c) or clause (d) of sub-section (1) or sub-section (2) of section 272-A, sub-section (1) of section 272-AA or ] [Inserted by Act 46 of 1986, Section 26 (w.e.f. 10.9.1986).][section 272-B or] [ Inserted by Act 20 of 2002, Section 106 (w.e.f

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

56,152 7,71,29,484 7,34,47,438 6,53,94,261 Due dates of Tax Audit 31-10-2015 17-10-2016 07-11-2017 31-10-2018 31-10-2019 Audit Uploaded 28-12-2016 30-03-2017 31-03-2018 15-03-2019 14-02-2020 Actual delay in days

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

56,152 7,71,29,484 7,34,47,438 6,53,94,261 Due dates of Tax Audit 31-10-2015 17-10-2016 07-11-2017 31-10-2018 31-10-2019 Audit Uploaded 28-12-2016 30-03-2017 31-03-2018 15-03-2019 14-02-2020 Actual delay in days

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

56,152 7,71,29,484 7,34,47,438 6,53,94,261 Due dates of Tax Audit 31-10-2015 17-10-2016 07-11-2017 31-10-2018 31-10-2019 Audit Uploaded 28-12-2016 30-03-2017 31-03-2018 15-03-2019 14-02-2020 Actual delay in days

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

56,152 7,71,29,484 7,34,47,438 6,53,94,261 Due dates of Tax Audit 31-10-2015 17-10-2016 07-11-2017 31-10-2018 31-10-2019 Audit Uploaded 28-12-2016 30-03-2017 31-03-2018 15-03-2019 14-02-2020 Actual delay in days

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

u/s 270A of the Act by NFAC arising out of different orders of NFAC for the respective above assessment years. 2. Facts of the case are that IBM is a multinational corporation, headquartered in the USA with multiple subsidiaries around the globe, including India. IBM foreign entities received notices under section 148/ section 143(2) of the Income

GOPAL KRISHNA KARODI SABBANA,DAKSHINA KANNADA vs. DY./ASST.COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE 2, MANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

56,152 7,71,29,484 7,34,47,438 6,53,94,261 Due dates of Tax Audit 31-10-2015 17-10-2016 07-11-2017 31-10-2018 31-10-2019 Audit Uploaded Actual delay in days

COMPAGNIE IBM FRANCE,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

u/s 270A of the Act by NFAC arising out of different orders of NFAC for the respective above assessment years. 2. Facts of the case are that IBM is a multinational corporation, headquartered in the USA with multiple subsidiaries around the globe, including India. IBM foreign entities received notices under section 148/ section 143(2) of the Income

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

u/s 270A of the Act by NFAC arising out of different orders of NFAC for the respective above assessment years. 2. Facts of the case are that IBM is a multinational corporation, headquartered in the USA with multiple subsidiaries around the globe, including India. IBM foreign entities received notices under section 148/ section 143(2) of the Income

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

u/s 270A of the Act by NFAC arising out of different orders of NFAC for the respective above assessment years. 2. Facts of the case are that IBM is a multinational corporation, headquartered in the USA with multiple subsidiaries around the globe, including India. IBM foreign entities received notices under section 148/ section 143(2) of the Income

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

u/s 270A of the Act by NFAC arising out of different orders of NFAC for the respective above assessment years. 2. Facts of the case are that IBM is a multinational corporation, headquartered in the USA with multiple subsidiaries around the globe, including India. IBM foreign entities received notices under section 148/ section 143(2) of the Income

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

u/s 270A of the Act by NFAC arising out of different orders of NFAC for the respective above assessment years. 2. Facts of the case are that IBM is a multinational corporation, headquartered in the USA with multiple subsidiaries around the globe, including India. IBM foreign entities received notices under section 148/ section 143(2) of the Income

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

u/s 270A of the Act by NFAC arising out of different orders of NFAC for the respective above assessment years. 2. Facts of the case are that IBM is a multinational corporation, headquartered in the USA with multiple subsidiaries around the globe, including India. IBM foreign entities received notices under section 148/ section 143(2) of the Income

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

u/s 270A of the Act by NFAC arising out of different orders of NFAC for the respective above assessment years. 2. Facts of the case are that IBM is a multinational corporation, headquartered in the USA with multiple subsidiaries around the globe, including India. IBM foreign entities received notices under section 148/ section 143(2) of the Income