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

201 of the Explanation 3 refers to the term Act were initiated in case of IBM India ‘reasonable cause’. Reliance can be - Receipts were offered to tax only after placed on decision of SC in Singapore a notice under section 148 of the Act Airlines Ltd. vs Commissioner of Income Tax [2022] 144 taxmann.com was issued, initiating the reassessment

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

201 of the Explanation 3 refers to the term Act were initiated in case of IBM India ‘reasonable cause’. Reliance can be - Receipts were offered to tax only after placed on decision of SC in Singapore a notice under section 148 of the Act Airlines Ltd. vs Commissioner of Income Tax [2022] 144 taxmann.com was issued, initiating the reassessment

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

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

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

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

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

201 of the\n'reasonable cause'. Reliance can be\nAct were initiated in case of IBM India\nplaced on decision of SC in Singapore\nReceipts were offered to tax only after\nAirlines Ltd. VS Commissioner of\na notice under section 148 of the Act\nIncome Tax [2022] 144 taxmann.com\nwas issued, initiating the reassessment

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

The appeals of the assessees are allowed

201 of the\nAct were initiated in case of IBM India\nExplanation 3 refers to the term\n'reasonable cause'. Reliance can be\nplaced on decision of SC in Singapore\nReceipts were offered to tax only after\na notice under section 148 of the Act\nwas issued, initiating the reassessment

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

The appeals of the assessees are allowed

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

IBM OSTERREICH INTIONATIONALE BUROMASCHINEN GESELLSCHAFT MBH,BANGALORE vs. DEPUTY COMMISSIONER OF INCOME TAX, INTERNATIONAL TAXATION-CIRCLE-1(2), BANGALORE

In the result, all the appeals of the assessees are allowed

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

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

201 of the\nAct were initiated in case of IBM India\n- Receipts were offered to tax only after\na notice under section 148 of the Act\nwas issued, initiating the reassessment

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

201 Hassan PAN NO : AAEFS4881R APPELLANT RESPONDENT Assessee by : Shri C. Ramesh, A.R. Revenue by : Ms. Neera Malhotra, D.R. Date of Hearing : 15.05.2024 Date of Pronouncement : 10.06.2024 ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 2 of 104 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: ITA Nos.1163 to 1165/Bang/2023 filed by the revenue

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

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

201 Hassan PAN NO : AAEFS4881R APPELLANT RESPONDENT Assessee by : Shri C. Ramesh, A.R. Revenue by : Ms. Neera Malhotra, D.R. Date of Hearing : 15.05.2024 Date of Pronouncement : 10.06.2024 ITA Nos.1156 & 1163 to 1166/Bang/2023 M/s. S. Ramachandra Setty & Sons, Hassan Page 2 of 104 O R D E R PER CHANDRA POOJARI, ACCOUNTANT MEMBER: ITA Nos.1163 to 1165/Bang/2023 filed by the revenue