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 153A empowers the Assessing Officer to assess or reassess the total income of six assessment years in question in separate assessment orders. (f) Once the assessment is reopened, the Assessing Officer can take note of the income disclosed in the earlier returns, any undisclosed income found during search or any other income which is not disclosed in the earlier

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 153A empowers the Assessing Officer to assess or reassess the total income of six assessment years in question in separate assessment orders. (f) Once the assessment is reopened, the Assessing Officer can take note of the income disclosed in the earlier returns, any undisclosed income found during search or any other income which is not disclosed in the earlier

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

Section 153A empowers the Assessing Officer to assess or reassess the total income of six assessment years in question in separate assessment orders. (f) Once the assessment is reopened, the Assessing Officer can take note of the income disclosed in the earlier returns, any undisclosed income found during search or any other income which is not disclosed in the earlier

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

25 March 2015. They also submitted that IBM Corporation is largest of the IBM Foreign Entities in the context of receipt of secondment reimbursements from India. This order has achieved finality since the same has neither been revised under section 263 nor has been reassessed

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

25 March 2015. They also submitted that IBM Corporation is largest of the IBM Foreign Entities in the context of receipt of secondment reimbursements from India. This order has achieved finality since the same has neither been revised under section 263 nor has been reassessed

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

25 March 2015. They also submitted that IBM Corporation is largest of the IBM Foreign Entities in the context of receipt of secondment reimbursements from India. This order has achieved finality since the same has neither been revised under section 263 nor has been reassessed

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

25 March 2015. They also submitted that IBM Corporation is largest of the IBM Foreign Entities in the context of receipt of secondment reimbursements from India. This order has achieved finality since the same has neither been revised under section 263 nor has been reassessed

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

25,28,401/- by making two disallowances in the\nassessment order viz. (a) disallowance of employee's share of\nprovident contribution u/s 36(1)(va) of the Act amounting to\nRs.16,61,049/- and (b) disallowance of education cess claimed as\ndeduction u/s 37 of the Act amounting to Rs.1,22,79,936/-. It is an\nundisputed fact that

DEPUTY COMMISSIONER OF INCOME TAX, (EXEMPTIONS), CIRCLE-1, BENGALURU vs. RASHTROTTHANA PARISHAT, BENGALURU

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

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyassessment Year: 2017=18

reassessed or recomputed in a preceding order. (11)No addition or disallowance of an amount shall form the basis for imposition of penalty, if such addition or disallowance has formed the basis of imposition of penalty in the case of the person for the same or any other assessment year. (12)The penalty referred to in sub-section (1) shall

MOHAMMED MUJEEB SIKANDER,MANGALORE vs. DCIT, CENTRAL CIRCLE (1), MANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassess income of such “other person” in accordance with the provisions of section 153A of the Act. 4.5 In the present case, the ld. AO being Deputy Commissioner of Income-tax Central Circle-1, Mangalore having recorded the satisfaction for proceedings u/s 153C of the Act after duly recording the satisfaction as follows: “A search was initiated under section

MOHAMMED MUJEEB SIKANDER,MANGALORE vs. DCIT, CENTRAL CIRCLE (1), MANGALORE

Bench: Shri Chandra Poojari & Smt. Beena Pillai

reassess income of such “other person” in accordance with the provisions of section 153A of the Act. 4.5 In the present case, the ld. AO being Deputy Commissioner of Income-tax Central Circle-1, Mangalore having recorded the satisfaction for proceedings u/s 153C of the Act after duly recording the satisfaction as follows: “A search was initiated under section

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

25 March 2015. They also submitted that IBM\nCorporation is largest of the IBM Foreign Entities in the context of\nreceipt of secondment reimbursements from India. This order has\nachieved finality since the same has neither been revised under\nsection 263 nor has been reassessed under section

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

25 March 2015. They also submitted that IBM\nCorporation is largest of the IBM Foreign Entities in the context of\nreceipt of secondment reimbursements from India. This order has\nachieved finality since the same has neither been revised under\nsection 263 nor has been reassessed under section

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

The appeals of the assessees are allowed

25 March 2015. They also submitted that IBM\nCorporation is largest of the IBM Foreign Entities in the context of\nreceipt of secondment reimbursements from India. This order has\nachieved finality since the same has neither been revised under\nsection 263 nor has been reassessed under section

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

The appeals of the assessees are allowed

25 March 2015. They also submitted that IBM\nCorporation is largest of the IBM Foreign Entities in the context of\nreceipt of secondment reimbursements from India. This order has\nachieved finality since the same has neither been revised under\nsection 263 nor has been reassessed under section

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

25 March 2015. They also submitted that IBM\nCorporation is largest of the IBM Foreign Entities in the context of\nreceipt of secondment reimbursements from India. This order has\nachieved finality since the same has neither been revised under\nsection 263 nor has been reassessed under section

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

reassess taking into consideration the\nother material in respect of completed assessments/unabated\nassessments. Meaning thereby, in respect of\ncompleted/unabated assessments, no addition can be made by\nthe AO in absence of any incriminating material found during\nthe course of search under section 132 or requisition under\nsection 132A of the Act, 1961. However, the\ncompleted/unabated assessments can be re-opened

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

25 March 2015. They also submitted that IBM\nCorporation is largest of the IBM Foreign Entities in the context of\nreceipt of secondment reimbursements from India. This order has\nachieved finality since the same has neither been revised under\nsection 263 nor has been reassessed under section