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

217 – 222 of PB) Operating System (supra) 3.13 Nevertheless, with respect to the section 201 proceedings initiated on IBM India on the same subject matter, while the appeals were pending before the ITAT and despite the fact that the Hon’ble ITAT constituted a Special Bench to hear the appeals, noting the judicial conflict in the views expressed by various

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

217 – 222 of PB)\nOperating\nSystem\n(supra)\n3.13\nNevertheless, with respect to the section 201 proceedings\ninitiated on IBM India on the same subject matter, while the appeals\nwere pending before the ITAT and despite the fact that the Hon'ble\nITAT constituted a Special Bench to hear the appeals, noting the\njudicial conflict in the views expressed

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

217 – 222 of PB) Operating System (supra) 3.13 Nevertheless, with respect to the section 201 proceedings initiated on IBM India on the same subject matter, while the appeals were pending before the ITAT and despite the fact that the Hon’ble ITAT constituted a Special Bench to hear the appeals, noting the judicial conflict in the views expressed by various

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

217 – 222 of PB)\nOperating\nSystem\n(supra)\n3.13\nNevertheless, with respect to the section 201 proceedings\ninitiated on IBM India on the same subject matter, while the appeals\nwere pending before the ITAT and despite the fact that the Hon'ble\nITAT constituted a Special Bench to hear the appeals, noting the\njudicial conflict in the views expressed

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

217 – 222 of PB)\nOperating\nSystem\n(supra)\n3.13 Nevertheless, with respect to the section 201 proceedings\ninitiated on IBM India on the same subject matter, while the appeals\nwere pending before the ITAT and despite the fact that the Hon'ble\nITAT constituted a Special Bench to hear the appeals, noting the\njudicial conflict in the views expressed

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

217 – 222 of PB)\nOperating\nSystem\n(supra)\n3.13 Nevertheless, with respect to the section 201 proceedings\ninitiated on IBM India on the same subject matter, while the appeals\nwere pending before the ITAT and despite the fact that the Hon'ble\nITAT constituted a Special Bench to hear the appeals, noting the\njudicial conflict in the views expressed

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

The appeals of the assessees are allowed

217 – 222 of PB)\nOperating\nSystem\n(supra)\n3.13 Nevertheless, with respect to the section 201 proceedings\ninitiated on IBM India on the same subject matter, while the appeals\nwere pending before the ITAT and despite the fact that the Hon'ble\nITAT constituted a Special Bench to hear the appeals, noting the\njudicial conflict in the views expressed

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

217 – 222 of PB) Operating System (supra) 3.13 Nevertheless, with respect to the section 201 proceedings initiated on IBM India on the same subject matter, while the appeals were pending before the ITAT and despite the fact that the Hon’ble ITAT constituted a Special Bench to hear the appeals, noting the judicial conflict in the views expressed by various

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

217 – 222 of PB) Operating System (supra) 3.13 Nevertheless, with respect to the section 201 proceedings initiated on IBM India on the same subject matter, while the appeals were pending before the ITAT and despite the fact that the Hon’ble ITAT constituted a Special Bench to hear the appeals, noting the judicial conflict in the views expressed by various

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

217 – 222 of PB)\nFavourable.\nDistinguishing\nChennai\nITAT\n9 October 2023\nNorthern\nOperating\nSystem\n(supra)\n3.13 Nevertheless, with respect to the section 201 proceedings\ninitiated on IBM India on the same subject matter, while the appeals\nwere pending before the ITAT and despite the fact that the Hon'ble\nITAT constituted a Special Bench to hear the appeals, noting

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

217 – 222 of PB)\nFavourable.\nDistinguishing\nChennai\nITAT\n9 October 2023\nNorthern\nOperating\nSystem\n(supra)\n3.13\nNevertheless, with respect to the section 201 proceedings\ninitiated on IBM India on the same subject matter, while the appeals\nwere pending before the ITAT and despite the fact that the Hon'ble\nITAT constituted a Special Bench to hear the appeals, noting

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

217 – 222 of PB)\nOperating\nSystem\n(supra)\n3.13\nNevertheless, with respect to the section 201 proceedings\ninitiated on IBM India on the same subject matter, while the appeals\nwere pending before the ITAT and despite the fact that the Hon'ble\nITAT constituted a Special Bench to hear the appeals, noting the\njudicial conflict in the views expressed

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

217 – 222 of PB)\nOperating\nSystem\n(supra)\n3.13 Nevertheless, with respect to the section 201 proceedings\ninitiated on IBM India on the same subject matter, while the appeals\nwere pending before the ITAT and despite the fact that the Hon'ble\nITAT constituted a Special Bench to hear the appeals, noting the\njudicial conflict in the views expressed

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

The appeals of the assessees are allowed

217 – 222 of PB)\nOperating\nSystem\n(supra)\n3.13 Nevertheless, with respect to the section 201 proceedings\ninitiated on IBM India on the same subject matter, while the appeals\nwere pending before the ITAT and despite the fact that the Hon'ble\nITAT constituted a Special Bench to hear the appeals, noting the\njudicial conflict in the views expressed

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

217 – 222 of PB)\nOperating\nSystem\n(supra)\n3.13\nNevertheless, with respect to the section 201 proceedings\ninitiated on IBM India on the same subject matter, while the appeals\nwere pending before the ITAT and despite the fact that the Hon'ble\nITAT constituted a Special Bench to hear the appeals, noting the\njudicial conflict in the views expressed

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

217 – 222 of PB)\nOperating\nSystem\n(supra)\n3.13\nNevertheless, with respect to the section 201 proceedings\ninitiated on IBM India on the same subject matter, while the appeals\nwere pending before the ITAT and despite the fact that the Hon'ble\nITAT constituted a Special Bench to hear the appeals, noting the\njudicial conflict in the views expressed

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

217 – 222 of PB)\nOperating\nSystem\n(supra)\n3.13 Nevertheless, with respect to the section 201 proceedings\ninitiated on IBM India on the same subject matter, while the appeals\nwere pending before the ITAT and despite the fact that the Hon'ble\nITAT constituted a Special Bench to hear the appeals, noting the\njudicial conflict in the views expressed

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

217 – 222 of PB)\nFavourable.\nDistinguishing\nNorthern\nOperating\nSystem\n(supra)\nChennai\nITAT\n9 October 2023\n\n3.13 Nevertheless, with respect to the section 201 proceedings\ninitiated on IBM India on the same subject matter, while the appeals\nwere pending before the ITAT and despite the fact that the Hon'ble\nITAT constituted a Special Bench to hear the appeals