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

221 (SC) – page 112-141 of case law reassessment proceedings. compilation wherein the SC (at page 117) - Reference to Explanation 3 to section has dealt with the aspect of ‘reasonable 271(1

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

221 (SC) – page 112-141 of case law reassessment proceedings. compilation wherein the SC (at page 117) - Reference to Explanation 3 to section has dealt with the aspect of ‘reasonable 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\nproceedings/\nduring the course of\nreassessment proceedings.\nReference to Explanation 3 to section\n271(1)(c) of the Act was upheld\n(Page 10/11 of the CIT(A)'s order)\nAirlines Ltd. VS Commissioner of\nIncome Tax [2022] 144 taxmann.com\n221 (SC) page 112-141 of case law\ncompilation wherein the SC (at page 117)\nhas dealt with

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\nproceedings/ during the course of\nreassessment proceedings.\nReference to Explanation 3 to section\n271(1)(c) of the Act was upheld\n(Page 10/11 of the CIT(A)'s order)\nThe CIT(A) has contended that mere\nacceptance of tax liability will not\npreclude the levy of the penalty on the\nassessee.\nThe CIT(A) has relied

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\nproceedings/ during the course of\nreassessment proceedings.\nReference to Explanation 3 to section\n271(1)(c) of the Act was upheld\n(Page 10/11 of the CIT(A)'s order)\nIn addition to the above, legal\nsubmissions, it is submitted that IBM\nIndia has reported such receipts in 3CEB\nExplanation 3 refers to the term\n'reasonable cause'. Reliance

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\nproceedings/ during the course of\nreassessment proceedings.\nReference to Explanation 3 to section\n271(1)(c) of the Act was upheld\n(Page 10/11 of the CIT(A)'s order)\nIn addition to the above, legal\nsubmissions, it is submitted that IBM\nIndia has reported such receipts in 3CEB\nExplanation 3 refers to the term\n'reasonable cause'. Reliance

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\nproceedings/ during the course of\nreassessment proceedings.\nReference to Explanation 3 to section\n271(1)(c) of the Act was upheld\n(Page 10/11 of the CIT(A)'s order)\nIn addition to the above, legal\nsubmissions, it is submitted that IBM\nIndia has reported such receipts in 3CEB\nExplanation 3 refers to the term\n'reasonable cause'. Reliance

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\nproceedings/ during the course of\nreassessment proceedings.\nReference to Explanation 3 to section\n271(1)(c) of the Act was upheld\n(Page 10/11 of the CIT(A)'s order)\nIn addition to the above, legal\nsubmissions, it is submitted that IBM\nIndia has reported such receipts in 3CEB\nExplanation 3 refers to the term\n'reasonable cause'. Reliance

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\n221 (SC) page 112-141 of case law\nproceedings/ during the course of\ncompilation wherein the SC (at page 117)\nreassessment proceedings.\nhas dealt with the aspect of 'reasonable\nReference to Explanation 3 to section\ncause". The Supreme Court has held that\n271(1)(c) of the Act was upheld\nwhere there are contradictory judicial\n(Page 10/11

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

reassessment\nproceedings/ during the course of\nreassessment proceedings.\nReference to Explanation 3 to section\n271(1)(c) of the Act was upheld\n(Page 10/11 of the CIT(A)'s order)\nIn addition to the above, legal\nsubmissions, it is submitted that IBM\nIndia has reported such receipts in 3CEB\nExplanation 3 refers to the term\n'reasonable cause'. Reliance

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

reassessment\nproceedings/ during the course of\nreassessment proceedings.\n\n- Reference to Explanation 3 to section\n271(1)(c) of the Act was upheld\n(Page 10/11 of the CIT(A)'s order)\n\n- The CIT(A) has contended that mere\nacceptance of tax liability will not\npreclude the levy of the penalty on the\nassessee

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

reassessment\nproceedings/ during the course of\nreassessment proceedings.\nReference to Explanation 3 to section\n271(1)(c) of the Act was upheld\n(Page 10/11 of the CIT(A)'s order)\nIn addition to the above, legal\nsubmissions, it is submitted that IBM\nIndia has reported such receipts in 3CEB\nExplanation 3 refers to the term\n'reasonable cause'. Reliance

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

reassessment\nproceedings/ during the course of\nreassessment proceedings.\nReference to Explanation 3 to section\n271(1)(c) of the Act was upheld\n(Page 10/11 of the CIT(A)'s order)\nIn addition to the above, legal\nsubmissions, it is submitted that IBM\nIndia has reported such receipts in 3CEB\nExplanation 3 refers to the term\n'reasonable cause'. Reliance

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\nproceedings/ during the course of\nreassessment proceedings.\nReference to Explanation 3 to section\n271(1)(c) of the Act was upheld\n(Page 10/11 of the CIT(A)'s order)\nIn addition to the above, legal\nsubmissions, it is submitted that IBM\nIndia has reported such receipts in 3CEB\nExplanation 3 refers to the term\n'reasonable cause'. Reliance

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

reassessment\n221 (SC) page 112-141 of case law\nproceedings/ during the course of\nreassessment proceedings.\ncompilation wherein the SC (at page 117)\nhas dealt with the aspect of 'reasonable\nReference to Explanation 3 to section\ncause". The Supreme Court has held that\n271(1)(c) of the Act was upheld\nwhere there are contradictory judicial\n(Page 10/11

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

The appeals of the assessees are allowed

reassessment\nproceedings/ during the course of\nreassessment proceedings.\nReference to Explanation 3 to section\n271(1)(c) of the Act was upheld\n(Page 10/11 of the CIT(A)'s order)\nIn addition to the above, legal\nsubmissions, it is submitted that IBM\nIndia has reported such receipts in 3CEB\nExplanation 3 refers to the term\n'reasonable cause'. Reliance

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

reassessment\nproceedings/ during the course of\nreassessment proceedings.\nReference to Explanation 3 to section\n271(1)(c) of the Act was upheld\n(Page 10/11 of the CIT(A)'s order)\nIn addition to the above, legal\nsubmissions, it is submitted that IBM\nIndia has reported such receipts in 3CEB\nExplanation 3 refers to the term\n'reasonable cause'. Reliance

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

reassessment\nproceedings/ during the course of\nreassessment proceedings.\nReference to Explanation 3 to section\n271(1)(c) of the Act was upheld\n(Page 10/11 of the CIT(A)'s order)\nIn addition to the above, legal\nsubmissions, it is submitted that IBM\nIndia has reported such receipts in 3CEB\nExplanation 3 refers to the term\n'reasonable cause'. Reliance