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 taxmann.com 595 (Karnataka HC), whereby the Assessee had presented an application under section 197, in respect to deductibility of tax on similar receipts - The CIT(A) highlighted that section 195(2) and section 197 of the Act are in the nature of safeguard sections to make sure that taxes are rightfully deducted on payments. - The CIT(A) has thereafter

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 taxmann.com 595 (Karnataka HC), whereby the Assessee had presented an application under section 197, in respect to deductibility of tax on similar receipts - The CIT(A) highlighted that section 195(2) and section 197 of the Act are in the nature of safeguard sections to make sure that taxes are rightfully deducted on payments. - The CIT(A) has thereafter

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

4 & 5 in for the AY 2010-11 and ITA No.1112/Bang/2022 for the AY 2012-13 (Two appeals only) in the case of Shri Reddy Veeranna and in ITA No.1111/Bang/2022 for the AY 2015-16 in the case of Smt. Reddy Sangeetha is with regard to treating the return of income filed by assessee in response to notice issued

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

4 & 5 in for the AY 2010-11 and ITA No.1112/Bang/2022 for the AY 2012-13 (Two appeals only) in the case of Shri Reddy Veeranna and in ITA No.1111/Bang/2022 for the AY 2015-16 in the case of Smt. Reddy Sangeetha is with regard to treating the return of income filed by assessee in response to notice issued

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

4 & 5 in for the AY 2010-11 and ITA No.1112/Bang/2022 for the AY 2012-13 (Two appeals only) in the case of Shri Reddy Veeranna and in ITA No.1111/Bang/2022 for the AY 2015-16 in the case of Smt. Reddy Sangeetha is with regard to treating the return of income filed by assessee in response to notice issued

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

4 & 5 in for the AY 2010-11 and ITA No.1112/Bang/2022 for the AY 2012-13 (Two appeals only) in the case of Shri Reddy Veeranna and in ITA No.1111/Bang/2022 for the AY 2015-16 in the case of Smt. Reddy Sangeetha is with regard to treating the return of income filed by assessee in response to notice issued

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

4 & 5 in for the AY 2010-11 and ITA No.1112/Bang/2022 for the AY 2012-13 (Two appeals only) in the case of Shri Reddy Veeranna and in ITA No.1111/Bang/2022 for the AY 2015-16 in the case of Smt. Reddy Sangeetha is with regard to treating the return of income filed by assessee in response to notice issued

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

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 issue was held against the assessee

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

4) or sub-section (5) of that Section. 9. Section 144 also provides for a best judgment assessment to be made under clause 1(b) (which is not relevant for the present case) and under clause 1(c) thereof. Section 144 (1)(c) provided that a best judgment assessment can be made by the assessing officer if the assessee having

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

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 issue was held against the assessee

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

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 issue was held against the assessee

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

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 issue was held against the assessee

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

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 issue was held against the assessee

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

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 issue was held against the assessee

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

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 issue was held against the assessee

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

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 issue was held against the assessee

KARNATAKA CHINMAYA SEVA TRUST,BENGALURU vs. DCIT-(EXEMPTIONS) CIRCLE-1, BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessmentyear:2016-17

4) of the Act on 18.1.2018, which is much beyond the due date of filing return as prescribed. Further, the assessee has also filed the audit report in form 10B dated 12.1.2018 belatedly on 18.1.2018. We also cannot brush aside the fact that the assessee has been granted registration u./s 12A of the Act by the ld. CIT, Karnataka

GOPAL S. PANDITH vs. DCIT,

In the result, all the appeals of the assessee are partly allowed

Bench: Shri A.K. Garodia & Shri Vijay Pal Rao

139, 147, 148, 149, 151 and 153 shall have no over-riding effect on this provision. When the new provisions for assessment or reassessment in case of search under Section 132 of the Act section. Even otherwise we find that the notice under Section 153A(1)(a) was issued on 24.9.2009 wherein the Assessing Officer has given time period