INCOME TAX OFFICER WARD-1 HASSAN, HASSAN vs. RAMACHANDRA SETTY AND SONGS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 34 of the Act that entries in the books of ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 52 of 104 account regularly kept in the course of business are relevant whenever they refer to a matter in which the Court has to enquire was subject to the salient proviso that such entries shall

M/S. S. RAMASHANDRA SETTY & SONS,HASSAN vs. INCOME TAX OFFICER, WARD-1 , HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 34 of the Act that entries in the books of ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 52 of 104 account regularly kept in the course of business are relevant whenever they refer to a matter in which the Court has to enquire was subject to the salient proviso that such entries shall

INCOME TAX OFFICER, W-1, HASSAN vs. RAMACHANDRA SETTY & SONS, HASSAN

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 34 of the Act that entries in the books of ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 52 of 104 account regularly kept in the course of business are relevant whenever they refer to a matter in which the Court has to enquire was subject to the salient proviso that such entries shall

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

reassessed under section 147 of the Act; 4.5.5 Assuming but not admitting, in case of conflicting rulings, the Assessee is entitled to place reliance on rulings favorable to him and ought not to be penalized for adopting a favourable view in the said issue. Relevant judicial precedents were discussed to justify that non-acceptance of the bonafide explanation offered

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

reassessed under section 147 of the Act; 4.5.5 Assuming but not admitting, in case of conflicting rulings, the Assessee is entitled to place reliance on rulings favorable to him and ought not to be penalized for adopting a favourable view in the said issue. Relevant judicial precedents were discussed to justify that non-acceptance of the bonafide explanation offered

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

reassessed under section 147 of the Act; 4.5.5 Assuming but not admitting, in case of conflicting rulings, the Assessee is entitled to place reliance on rulings favorable to him and ought not to be penalized for adopting a favourable view in the said issue. Relevant judicial precedents were discussed to justify that non-acceptance of the bonafide explanation offered

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

reassessed under section 147 of the Act; 4.5.5 Assuming but not admitting, in case of conflicting rulings, the Assessee is entitled to place reliance on rulings favorable to him and ought not to be penalized for adopting a favourable view in the said issue. Relevant judicial precedents were discussed to justify that non-acceptance of the bonafide explanation offered

IIFL SAMASTA FINANCE LIMITED ,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-6(1)(1), BANGALORE

In the result, the appeal filed by the assessee is allowed

158\nTaxmann.com 80 (Rajasthan) held that the Appellant is rightly\nentitled to benefit of immunity as per the provisions of section\n270AA of Income Tax Act.\n8) For the above and any other grounds that may be advanced at\nthe time of hearing, the Appellant prays Honourable ITAT to delete the\npenalty levied.\"\nAny consequential relief, to which the Appellant

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

158-BC,\nnotice under Section 143(2) should be issued within one year from the date of\nfiling of block return. Omission on the part of the assessing authority to issue\nnotice under Section 143(2) cannot be a procedural irregularity and the same is\nnot curable and, therefore, the requirement of notice under Section 143(2) cannot\nbe dispensed

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

reassessed under section 147\nof the Act;\n4.5.5 Assuming but not admitting, in case of conflicting rulings, the\nAssessee is entitled to place reliance on rulings favorable to him and\nought not to be penalized for adopting a favourable view in the said\nissue. Relevant judicial precedents were discussed to justify that\nnon-acceptance of the bonafide explanation offered

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

158-BC, notice under Section 143(2) should be issued within one year from the date of filing of block return. Omission on the part of the assessing authority to issue notice under Section 143(2) cannot be a procedural irregularity and the same is not curable and, therefore, the requirement of notice under Section 143(2) cannot be dispensed

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubey

158-BC, notice under Section 143(2) should be issued within one year from the date of filing of block return. Omission on the part of the assessing authority to issue notice under Section 143(2) cannot be a procedural irregularity and the same is not curable and, therefore, the requirement of notice under Section 143(2) cannot be dispensed

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

reassessed under section 147\nof the Act;\n4.5.5 Assuming but not admitting, in case of conflicting rulings, the\nAssessee is entitled to place reliance on rulings favorable to him and\nought not to be penalized for adopting a favourable view in the said\nissue. Relevant judicial precedents were discussed to justify that\nnon-acceptance of the bonafide explanation offered

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

The appeals of the assessees are allowed

reassessed under section 147\nof the Act;\n4.5.5 Assuming but not admitting, in case of conflicting rulings, the\nAssessee is entitled to place reliance on rulings favorable to him and\nought not to be penalized for adopting a favourable view in the said\nissue. Relevant judicial precedents were discussed to justify that\nnon-acceptance of the bonafide explanation offered

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

The appeals of the assessees are allowed

reassessed under section 147\nof the Act;\n4.5.5 Assuming but not admitting, in case of conflicting rulings, the\nAssessee is entitled to place reliance on rulings favorable to him and\nought not to be penalized for adopting a favourable view in the said\nissue. Relevant judicial precedents were discussed to justify that\nnon-acceptance of the bonafide explanation offered

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

reassessed under section 147\nof the Act;\n4.5.5 Assuming but not admitting, in case of conflicting rulings, the\nAssessee is entitled to place reliance on rulings favorable to him and\nought not to be penalized for adopting a favourable view in the said\nissue. Relevant judicial precedents were discussed to justify that\nnon-acceptance of the bonafide explanation offered

MR. D K SHIVAKUMAR,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE- 1(4), BANGALORE

In the result, we allow appeal filed by the assessee

158 ITR 826 and the\npremium money noted of Rs.3,48,33,582/- was treated as additional\nincome received at the time of entering into purchase agreement in\nrespect of 20 shops at Madiwala Commercial Plaza during the\n Assessment Year 2006-07 and the said premium was added as\nunexplained income for this AY in terms of 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

reassessed under section 147\nof the Act;\n4.5.5 Assuming but not admitting, in case of conflicting rulings, the\nAssessee is entitled to place reliance on rulings favorable to him and\nought not to be penalized for adopting a favourable view in the said\nissue. Relevant judicial precedents were discussed to justify that\nnon-acceptance of the bonafide explanation offered