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

139(1) of the Act was not filed and receipts were offered to tax during the reassessment proceedings − Category C: 271(1)(c) case where original return under section

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

139(1) of the Act was not filed and receipts were offered to tax during the reassessment proceedings − Category C: 271(1)(c) case where original return under section

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

139 of the Act - Receipts were offered to tax only after proceedings under section 201 of the Act were initiated in case of IBM India - Receipts were offered to tax only after a notice under section 148 of the Act was issued, initiating the reassessment proceedings/ during the course of reassessment proceedings. - Reference to Explanation 3 to section 271(1

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

139 of the Act Receipts were offered to tax only after proceedings under section 201 of the Act were initiated in case of IBM India Receipts were offered to tax only after a notice under section 148 of the Act was issued, initiating the reassessment proceedings/ during the course of reassessment proceedings. Reference to Explanation 3 to section 271(1

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-6(2)(1), BANGALORE vs. SRI C GANGADHARA MURTHY , BANGALORE

In the result, the appeal filed by the Revenue is allowed for statistical purpose

Bench: Shri N.V. Vasudevan & Shri Laxmi Prasad Sahuthe Dy. Commissioner Of Vs Shri C. Gangadhara Murthy Income-Tax, No. 322, 3Rd A Corss, 2Nd Block Circle - 6(2)(1) 3Rd Stage, Basaveshwaranagar Bangalore . Bangalore 560079. Pan – Agipg 2668 N (Appellant) (Respondent)

139 or in response to a notice issued under sub-section (1) of section 142 or section 148 or to disclose fully and truly all material facts necessary for his assessment for that assessment year. Explanation 1.—Production before the Assessing Officer of account books or other evidence from which material evidence could with due diligence have been discovered

SUNITA MADHOK ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), , BANGALORE

In the result, the appeals by the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

139, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section 142 or sub-section (2) of section 143 or after the completion of the assessment, whichever is earlier; ITA Nos.554 & 555/Bang/2018 Page 18 of 64 (b) where he has made no such return, after the expiry

SUNITA MADHOK ,BANGALORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(2)(1), BANGALORE

In the result, the appeals by the assessee are partly allowed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

139, after the expiry of one month from the date on which he was served with a notice under sub-section (1) of section 142 or sub-section (2) of section 143 or after the completion of the assessment, whichever is earlier; ITA Nos.554 & 555/Bang/2018 Page 18 of 64 (b) where he has made no such return, after the expiry

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

139 of the Act Receipts were offered to tax only after proceedings under section 201 of the Act were initiated in case of IBM India Receipts were offered to tax only after a notice under section 148 of the Act was issued, initiating the reassessment proceedings/ during the course of reassessment proceedings. Reference to Explanation 3 to section 271(1

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

139 of the Act Receipts were offered to tax only after proceedings under section 201 of the Act were initiated in case of IBM India Receipts were offered to tax only after a notice under section 148 of the Act was issued, initiating the reassessment proceedings/ during the course of reassessment proceedings. Reference to Explanation 3 to section 271(1

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

139 of the Act Receipts were offered to tax only after proceedings under section 201 of the Act were initiated in case of IBM India Receipts were offered to tax only after a notice under section 148 of the Act was issued, initiating the reassessment proceedings/ during the course of reassessment proceedings. Reference to Explanation 3 to section 271(1

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

139 of the Act Receipts were offered to tax only after proceedings under section 201 of the Act were initiated in case of IBM India Receipts were offered to tax only after a notice under section 148 of the Act was issued, initiating the reassessment proceedings/ during the course of reassessment proceedings. Reference to Explanation 3 to section 271(1

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

139 of the Act Receipts were offered to tax only after proceedings under section 201 of the Act were initiated in case of IBM India Receipts were offered to tax only after a notice under section 148 of the Act was issued, initiating the reassessment proceedings/ during the course of reassessment proceedings. Reference to Explanation 3 to section 271(1

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

139(1) of the Act was not filed and receipts were offered to tax during the reassessment proceedings Category C: 271(1)(c) case where original return under section

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

139(1) of the Act was not filed and receipts were offered to tax during the reassessment proceedings Category C: 271(1)(c) case where original return under section

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

139 of the Act\nReceipts were offered to tax only after\nproceedings under section 201 of the\nAct were initiated in case of IBM India\nReceipts were offered to tax only after\na notice under section 148 of the Act\nwas issued, initiating the reassessment\nproceedings/ during the course of\nreassessment proceedings.\nReference to Explanation 3 to section\n271(1

NEETA BHAMBHANI,BENGALURU vs. DCIT, (IT), CIRCLE-1(1), BENGALURU

In the result, I pass the following:-

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

139 of the Act. (Proviso 3 to Section 148) NITHAN RAJ T.N. CIRCLE 7(1)(1), BANGALORE" 3. The notice itself indicates that it is issued for the Assessment Year 2017-18 and is admittedly issued on 7.5.2024. Learned counsel appearing for the petitioner IT(IT)A No.3124/Bang/2025 Neeta Bhambhani, Bengaluru Page 20 of 24 submits that the notice

CHIKKAMUDNOOR MILK PRODUCERS CO-OPERATIVE SOCIETY LIMITED, ,CHIKKAMUDNOOR vs. INCOME TAX OFFICER, WARD-1 , PUTTUR

In the result appeal of the assessee is dismissed

Bench: Shri Prashant Maharishiassessment Year : 2019-20

reassessment intimation passed u/s 154 of the Act where in in intimation order under section 143 (1) of the income tax act 1961 dated 27 June 2023 passed by the central processing Centre, assesseee sought rectification for allowance of deduction u/s 80 P of the act despite filing Return of income beyond due date u/s 139

KEDAMBADI MILK PRODUCERS CO-OPERATIVE WOMEN SOCIETY LIMITED,KEDAMBADI vs. INCOME TAX OFFICER WARD 1 PUTTUR, PUTTUR

In the result appeal of the assessee is dismissed

Bench: Shri Prashant Maharishiassessment Year : 2019-20

reassessment intimation passed u/s 154 of the Act where in in intimation order under section 143 (1) of the income tax act 1961 dated 27 June 2023 passed by the central processing Centre, assesseee sought rectification for allowance of deduction u/s 80 P of the act despite filing Return of income beyond due date u/s 139