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

TDS AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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

TDS AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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

TDS AO as per section 197 of the Act in order to understand its tax liability. 4.2 Specific observation by the AO with respect to penalty under section 271(1)(c) of the Act 4.2.1 The AO in the penalty order has confirmed that the Assessee has ‘concealed’ particulars of income under section 271

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

TDS AO as per section 197 of the Act in order to understand its tax liability. 4.2 Specific observation by the AO with respect to penalty under section 271(1)(c) of the Act 4.2.1 The AO in the penalty order has confirmed that the Assessee has ‘concealed’ particulars of income under section 271

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

TDS AO as per section 197 of the Act in order to understand its tax liability. 4.2 Specific observation by the AO with respect to penalty under section 271(1)(c) of the Act 4.2.1 The AO in the penalty order has confirmed that the Assessee has ‘concealed’ particulars of income under section 271

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

TDS AO as per section 197 of the Act in order to understand its tax liability. 4.2 Specific observation by the AO with respect to penalty under section 271(1)(c) of the Act 4.2.1 The AO in the penalty order has confirmed that the Assessee has ‘concealed’ particulars of income under section 271

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

The appeals of the assessees are allowed

TDS AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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

TDS AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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

The appeals of the assessees are allowed

TDS AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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

TDS AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

M/S. SRI. MUTHU CINE SERVICE,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE -2(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

u/s 271(1)(c)/270A of the Act 6. 6 months from the 31.12.2021 31.12.2021 31.12.2021 31.12.2021 31.12.2021 end of the month in which action for imposition of penalty initiated 7. Decision Time barred Time Time barred Time barred Time barred barred M/s. Sri Muthu Cine Service, Bangalore 6.1 Before proceeding further, it is apposite here to take note

M/S. SRI. MUTHU CINE SERVICE,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-2(1), BENGALURU

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

u/s 271(1)(c)/270A of the Act 6. 6 months from the 31.12.2021 31.12.2021 31.12.2021 31.12.2021 31.12.2021 end of the month in which action for imposition of penalty initiated 7. Decision Time barred Time Time barred Time barred Time barred barred M/s. Sri Muthu Cine Service, Bangalore 6.1 Before proceeding further, it is apposite here to take note

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

TDS AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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

TDS AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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

TDS AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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

TDS AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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

TDS AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct

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

TDS AO as per\nsection 197 of the Act in order to understand its tax liability.\n4.2 Specific observation by the AO with respect to penalty\nunder section 271(1)(c) of the Act\n4.2.1 The AO in the penalty order has confirmed that the Assessee\nhas 'concealed' particulars of income under section 271(1)(c) of the\nAct