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

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 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

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

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

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

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 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

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

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 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

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

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

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 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

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

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

KRISHNAMURTHY L/R BY SMT. NAGARATHNAMMA,BANGALORE vs. DCIT,CIRCLE-2(1), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan Kassessment Year : 2012-13 Shri. Krishnamurthy, Vs. Dcit, Represented By His Lr Smt. Nagarathnamma, Circle –2(1), No.152, 2Nd Floor, Hanuman Chambers, Bangalore. 7Th Cross, 2Nd Main, Chamarajpet, Bangalore – 560 018. Pan : Admpk 2463 J Appellant Respondent Assessee By : Shri. Ravishankar S. V, Advocate Revenue By : Shri. Balusamy N, Jcit(Dr)(Itat), Bangalore. Date Of Hearing : 22.07.2025 Date Of Pronouncement : 28.08.2025

section 139(9) of the Act so that the defective return cannot be considered for completing the assessment / reassessment by the AO. Therefore

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

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

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