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

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 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

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

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

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

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

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

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

The appeals of the assessees are allowed

section 139(1) of the Act was\nnot filed and receipts were offered to tax during the reassessment proceedings\nIBM

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

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

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

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

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

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

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

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

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

The appeals of the assessees are allowed

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

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

section 139(1) of the Act was\nnot filed and receipts were offered to tax during the reassessment proceedings\nIBM

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

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

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

reassessment\n221 (SC) wherein the SC has dealt with\nproceedings/ during the course of\nthe aspect of ‘reasonable cause". IBM\nreassessment proceedings.\nforeign entities had reasonable cause to\nReference to Explanation 3 to section\nnot offer the receipts to tax in the return\n271(1)(c) of the Act was upheld\nunder section 139

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

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

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

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

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

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

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(1) of the Act was\nnot filed and receipts were offered to tax during the reassessment proceedings\n\nIBM

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

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