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

section 139 of the Act and has made full disclosure of income only in the reassessment proceedings under section 148 of the Act. 4.2.2 The AO in concluding

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

section 139 of the Act and has made full disclosure of income only in the reassessment proceedings under section 148 of the Act. 4.2.2 The AO in concluding

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

139, which has been specifically over-ridden in the first part of the section. At this juncture, the scope of the assessment to be made u/s. 153A of the Act is relevant. These are special Smt. Reddy Sangeetha, Bangalore ITA Nos.1112 & 1113/Bang/2022 & ITA Nos.1145 & 1146/Bang/2022 Shri Reddy Veeranna, Bangalore Page 12 of 39 provisions for making an assessment or reassessment

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

139, which has been specifically over-ridden in the first part of the section. At this juncture, the scope of the assessment to be made u/s. 153A of the Act is relevant. These are special Smt. Reddy Sangeetha, Bangalore ITA Nos.1112 & 1113/Bang/2022 & ITA Nos.1145 & 1146/Bang/2022 Shri Reddy Veeranna, Bangalore Page 12 of 39 provisions for making an assessment or reassessment

SMT. REDDY SANGEETHA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

139, which has been specifically over-ridden in the first part of the section. At this juncture, the scope of the assessment to be made u/s. 153A of the Act is relevant. These are special Smt. Reddy Sangeetha, Bangalore ITA Nos.1112 & 1113/Bang/2022 & ITA Nos.1145 & 1146/Bang/2022 Shri Reddy Veeranna, Bangalore Page 12 of 39 provisions for making an assessment or reassessment

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

139, which has been specifically over-ridden in the first part of the section. At this juncture, the scope of the assessment to be made u/s. 153A of the Act is relevant. These are special Smt. Reddy Sangeetha, Bangalore ITA Nos.1112 & 1113/Bang/2022 & ITA Nos.1145 & 1146/Bang/2022 Shri Reddy Veeranna, Bangalore Page 12 of 39 provisions for making an assessment or reassessment

SRI. REDDY VEERANNA,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-1(3), BENGALURU

Bench: Shri Chandra Poojari & Smt. Beena Pillai

139, which has been specifically over-ridden in the first part of the section. At this juncture, the scope of the assessment to be made u/s. 153A of the Act is relevant. These are special Smt. Reddy Sangeetha, Bangalore ITA Nos.1112 & 1113/Bang/2022 & ITA Nos.1145 & 1146/Bang/2022 Shri Reddy Veeranna, Bangalore Page 12 of 39 provisions for making an assessment or reassessment

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

section 139 of the Act and has made full disclosure\nof income only in the reassessment proceedings under section 148 of\nthe

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

section 139 of the Act and has made full disclosure\nof income only in the reassessment proceedings under section 148 of\nthe

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

section 139 of the Act and has made full disclosure\nof income only in the reassessment proceedings under section 148 of\nthe

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

section 139 of the Act and has made full disclosure\nof income only in the reassessment proceedings under section 148 of\nthe

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

section 139 of the Act and has made full disclosure\nof income only in the reassessment proceedings under section 148 of\nthe

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

section 139 of the Act and has made full disclosure\nof income only in the reassessment proceedings under section 148 of\nthe

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

The appeals of the assessees are allowed

section 139 of the Act and has made full disclosure\nof income only in the reassessment proceedings under section 148 of\nthe

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

section 139 of the Act and has made full disclosure\nof income only in the reassessment proceedings under section 148 of\nthe

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

section 139 of the Act and has made full disclosure\nof income only in the reassessment proceedings under section 148 of\nthe

MR. D K SHIVAKUMAR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

In the result, we allow appeal filed by the assessee

139, 147, 148, 149, 151 and 153'. Thus if there is any contradiction\nbetween Sections 153C and 148, in that eventuality, Section 148 shall give way to\nSection 153C. There is a reason for saying so because if a notice u/s.153C is issued to\nhe third party (assessee), then the AO may assess or reassess

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

section 139 of the Act and has made full disclosure\nof income only in the reassessment proceedings under section 148 of\nthe