BANDIGADI CHANDRAPPASHETTY RAJASHEKARAPPA,SHIMOGA vs. INCOME TAX OFFICER, WARD-1 , SHIMOGA

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can‟t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

SRI. BANDIGADI CHANDRAPPASHETTY RAJASHEKARA,SHIVAMOGGA vs. INCOME TAX OFFICER, WARD-4, SHIVAMOGGA

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can‟t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

BANDIGADI CHANDRAPPASHETTY RAJASHEKARAPPA,SHIMOGA vs. INCOME TAX OFFICER, WARD-1 , SHIMOGA

In the result, the appeal of the assessee is partly allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

reassess the earlier assessment in terms of section 147 or carry out rectification u/s 154 of the Act. He can‟t usurp the power of the CIT and recommend a revision. No overlapping of powers of the authorities under the Act can be permitted. As the revision proceedings in this case have triggered with the AO sending a proposal

BHARATH BAFNA ,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX-2 , BENGALURU

In the result, the appeal of the assessee is allowed

Bench: Shri Prashant Maharishi & Shri Soundararajan K.Assessment Year : 2017-18

revise the order u/s. 263 of the Act by the ld. PCIT. 7. The ld. CIT(DR) submits that when in the reassessment

HARISHA,MYSORE vs. PCIT (CENTRAL), BANGALORE, BANGALORE

In the result, appeal of the assessee is allowed

Bench: Shri Chandra Poojari & Shri Soundararajan K.Assessment Year: 2019-20

revision u/s 263 of the Act. The ld. A.R. also argued about the other grounds on merits and also filed a paper book and also relied on the order of this Tribunal in ITA Nos.6 & 7/Bang/2021 dated 21.9.2022 for the AY 2013-14 in the case of Bashir Ahmed Abdurrahman Matte Vs. PCIT. 4. The ld. D.R. relied

SHRI. POLLAMREDDY SREEDHAR REDDY,BENGALURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-1, BENGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year: 2018-19

revision of the order. This view is supported by the Hon'ble Pollam Reddy Shreedhar Reddy, Bangalore Page 5 of 16 Supreme Court in the case of Malabar Industrial Co. Ltd. v CIT (243 ITR 83). 4. The ld. D.R. submitted that AO has not made proper enquiry on the issue dealt by the ld. Principal CIT and therefore, Deputy

THAYAPPA BALAKRISHNA,BANGALORE vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, BENGALURU-1, BENGALURU

In the result, the appeal filed by the assessee stands allowed

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2014-15 Shri Thayappa Balakrishna, No. 987, 11Th Main, The Principal 1St Block, Commissioner Of 3Rd Stage, Income-Tax, Basaveshwaranagar, Bengaluru – 1. Vs. Bangalore – 560 079. Pan: Abdpb4893N Appellant Respondent : Shri Ravi Shankar .S.V, Assessee By Advocate Revenue By : Shri D.K. Mishra, Cit-Dr

reassessment order was passed by considering the reasons recorded on the facts and circumstances of the case. 8. Without prejudice the learned Pr. Commissioner failed to appreciate that if at all the department ought to have initiated the proceedings under section 263 of the Act against the assessment order passed u/s 143(3) of the Act dated

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

revised under section 263 nor has been reassessed under section 147 of the Act. 3.5 Subsequent to the above, the issue on taxability payments to seconded employees was revisited in the Hon’ble Delhi HC decision in the case of Centrica India Offshore (P.) Ltd. vs CIT [2014] 44 taxmann.com 300 (Delhi HC) dated 25 April 2014, wherein the said

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

revised under section 263 nor has been reassessed under section 147 of the Act. 3.5 Subsequent to the above, the issue on taxability payments to seconded employees was revisited in the Hon’ble Delhi HC decision in the case of Centrica India Offshore (P.) Ltd. vs CIT [2014] 44 taxmann.com 300 (Delhi HC) dated 25 April 2014, wherein the said

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

revised under section 263 nor has been reassessed under section 147 of the Act. 3.5 Subsequent to the above, the issue on taxability payments to seconded employees was revisited in the Hon’ble Delhi HC decision in the case of Centrica India Offshore (P.) Ltd. vs CIT [2014] 44 taxmann.com 300 (Delhi HC) dated 25 April 2014, wherein the said

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

revised under section 263 nor has been reassessed under section 147 of the Act. 3.5 Subsequent to the above, the issue on taxability payments to seconded employees was revisited in the Hon’ble Delhi HC decision in the case of Centrica India Offshore (P.) Ltd. vs CIT [2014] 44 taxmann.com 300 (Delhi HC) dated 25 April 2014, wherein the said

M/S. SHIVA FERRIC PRIVATE LIMITED,BANGALORE vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), BENGALURU

The appeal is allowed

Bench: Shri George George K & Ms. Padmavathy Sassessment Year : 2012-13 M/S. Shiva Ferric Pvt. Ltd., No. 193, 4Th Floor, Shiv The Principal Sadan Outer Ring Road, Commissioner Of B. Narayanapura, Income-Tax [Central], Bangalore – 560 016. Bengaluru. Vs. Pan: Aaics4564L Appellant Respondent Assessee By : Ms. Sunaina Bhatia, Ca Revenue By : Ms. Neera Malhotra, Cit-Dr Date Of Hearing : 17-01-2023 Date Of Pronouncement : 24-01-2023 Order Per Padmavathy S

revised under 263 of I T Act. Further, it is also claimed that order passed by AO cannot be deemed to be erroneous as the conditions of explanation 2 to section 263 are not satisfied. 9.The claim made by assessee are thoroughly considered. The addition made by the assessing officer in the reassessment order on account of unexplained share premium

MUNIYAPPA MUNIRAJU ,BENGALURU vs. PR. COMMISSIONER OF INCOME TAX, BENGALURU-2, BENGALURU

In the result, appeal filed by the assessee is allowed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2017-18 Shri. Muniyappa Muniraju, Vs. Pr. Cit, No.1/3, 1St Cross, Muni Narasimhaiah Bangalore - 2. Garden, Chocolate Factory Main Road, Btm I Stage, Bangalore – 560 029, Karnataka. Pan : Anjpm 0458 N Appellant Respondent Assessee By : Shri. Narendra Sharma, Advocate Revenue By : Shri. Muthu Shankar, Cit(Dr)(Itat), Bangalore. Date Of Hearing : 04.09.2025 Date Of Pronouncement : 11.09.2025

reassessment passed directed the learned assessing to make fresh assessment.  The learned assessing officer pursuant to the order of revision passed by the Hon’ble Principal Commissioner of Income-tax, under section 263 of the Act, dated 12/03/2024, issued various statutory notices calling for details and explanations. The learned assessing officer in the impugned proceedings of give effect

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

revised under\nsection 263 nor has been reassessed under section 147 of the Act;\n3.5 Subsequent to the above, the issue on taxability payments to\nseconded employees was revisited in the Hon'ble Delhi HC decision\nin the case of Centrica India Offshore (P.) Ltd. vs CIT [2014] 44\ntaxmann.com 300 (Delhi HC) dated 25 April 2014, wherein the said

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

The appeals of the assessees are allowed

revised under\nsection 263 nor has been reassessed under section 147 of the Act.\n3.5 Subsequent to the above, the issue on taxability payments to\nseconded employees was revisited in the Hon'ble Delhi HC decision\nin the case of Centrica India Offshore (P.) Ltd. vs CIT [2014] 44\ntaxmann.com 300 (Delhi HC) dated 25 April 2014, wherein the said

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

revised under\nsection 263 nor has been reassessed under section 147 of the Act.\n3.5\nSubsequent to the above, the issue on taxability payments to\nseconded employees was revisited in the Hon'ble Delhi HC decision\nin the case of Centrica India Offshore (P.) Ltd. vs CIT [2014] 44\ntaxmann.com 300 (Delhi HC) dated 25 April 2014, wherein the said

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

revised under\nsection 263 nor has been reassessed under section 147 of the Act.\n3.5\nSubsequent to the above, the issue on taxability payments to\nseconded employees was revisited in the Hon'ble Delhi HC decision\nin the case of Centrica India Offshore (P.) Ltd. vs CIT [2014] 44\ntaxmann.com 300 (Delhi HC) dated 25 April 2014, wherein the said

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

revised under\nsection 263 nor has been reassessed under section 147 of the Act.\n\n3.5\nSubsequent to the above, the issue on taxability payments to\nseconded employees was revisited in the Hon'ble Delhi HC decision\nin the case of Centrica India Offshore (P.) Ltd. vs CIT [2014] 44\ntaxmann.com 300 (Delhi HC) dated 25 April 2014, wherein