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

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

reassessment orders under section 143(3) read with section 147 of the Act/ assessment order under section 143(3) of the Act were issued along with show- cause notices for imposing penalty under section 271(1

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

reassessment orders under section 143(3) read with section 147 of the Act/ assessment order under section 143(3) of the Act were issued along with show- cause notices for imposing penalty under section 271(1

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

reassessment orders under section 143(3) read with section 147 of the Act/ assessment order under section 143(3) of the Act were issued along with show- cause notices for imposing penalty under section 271(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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassessment orders under section 143(3) read with section 147 of the Act/ assessment order under section 143(3) of the Act were issued along with show- cause notices for imposing penalty under section 271(1

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

The appeals of the assessees are allowed

reassessment orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(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

reassessment with a new regime. The first proviso to Section 149 does not expressly bar the application of Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. Section 3 of Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 applies to the entire Income-Tax Act, including Sections

INTACT DEVELOPERS PRIVATE LIMITED,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(2), BANGALORE

Accordingly, the appeals of the assessee for the AY 2015-16\nto AY 2017-18 are allowed

reassessment proceedings. This failure is jurisdictional and not curable, rendering the assessment order under Section 144 r.w.s 147 void.", "result": "Allowed", "sections": [ "147", "148", "143(2)", "144", "143(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

reassessment orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(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

reassessment orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1

INMOBI TECHNOLOGY SERVICES PRIVATE LIMITED,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE3(1)(1), BANGALORE

reassessment or recomputation or fresh assessment, as the case may be, expires'. Since the time limit for passing of the order by the TPO is not direct but is linked with the time limit as per section 153, the legislature did not insert any sunset clause in section 153, which would have otherwise made the provision of sub-section

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), MANGALORE vs. KARNATAKA BANK LIMITED., MANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

143(3) by itself being such a finding, based on the satisfaction or otherwise, of the Assessing Officer and no separate order finding on this count is envisaged as per the provisions of law. 7. The CIT(A) failed to appreciate that the disallowance is made after examining all the issues and the AO has also relied upon the decision

M/S. KARNATAKA BANK LIMITED,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX. CIRCLE- 2(1), MANGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

143(3) by itself being such a finding, based on the satisfaction or otherwise, of the Assessing Officer and no separate order finding on this count is envisaged as per the provisions of law. 7. The CIT(A) failed to appreciate that the disallowance is made after examining all the issues and the AO has also relied upon the decision

INTACT DEVELOPERS PRIVATE LIMITED ,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(2), BANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

1) If the time for issuance of the notice under Section 143(2) of the Act has expired or the time for completing the reassessment

INTACT DEVELOPERS PRIVATE LIMITED,BANGALORE vs. DCIT, CENTRAL CIRCLE-1(2), BANGALORE

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

1) If the time for issuance of the notice under Section 143(2) of the Act has expired or the time for completing the reassessment

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

reassessment orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(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

reassessment orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(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 orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(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

reassessment orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1