DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1, MANGALORE vs. L JAVERCHAND JEWELLERS PRIVATE LIMITED, MUMBAI

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

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2019-20 L. Javerchand Jewellers Pvt. Ltd. No.1, 2Nd Floor & 3Rd Floor, Choksi Chamber Dcit 1Stagyari Lane Vs. Central Circle-1 Zaveri Bazar Mangaluru Mumbai 400 002

250 of the Income Tax Act, 1961 ( in short “The Act”) for the assessment year ( in short “AY”) 2019-20. 2. The Revenue has raised the following grounds of appeal: L. Javerchand Jewellers Pvt. Ltd., Mumbai Page 2 of 17 3. Before leaping straightway to the penalty proceedings, it is very much pertinent here to discuss with regard

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

reassessment proceedings. - The CIT(A) has distinguished the facts of the case from Karnataka HC’s ruling in Manjunatha Cotton & Ginning Factory [2013] 35 Taxmann.com 250 (Karnataka HC) - The CIT(A) has concluded that the provisions of 270A(8) need not be invoked and that the case of the Assessee is covered under section 270A

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

reassessment proceedings. - The CIT(A) has distinguished the facts of the case from Karnataka HC’s ruling in Manjunatha Cotton & Ginning Factory [2013] 35 Taxmann.com 250 (Karnataka HC) - The CIT(A) has concluded that the provisions of 270A(8) need not be invoked and that the case of the Assessee is covered under section 270A

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

reassessment proceedings. - The CIT(A) has distinguished the facts of the case from Karnataka HC’s ruling in Manjunatha Cotton & Ginning Factory [2013] 35 Taxmann.com 250 (Karnataka HC) - The CIT(A) has concluded that the provisions of 270A(8) need not be invoked and that the case of the Assessee is covered under section 270A

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

reassessment proceedings. - The CIT(A) has distinguished the facts of the case from Karnataka HC’s ruling in Manjunatha Cotton & Ginning Factory [2013] 35 Taxmann.com 250 (Karnataka HC) - The CIT(A) has concluded that the provisions of 270A(8) need not be invoked and that the case of the Assessee is covered under section 270A

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

250 of the Act. 2. In first three appeals, the grounds are common except figures. Hence, we extract the grounds raised by the revenue in ITA No.1163/Bang/2024 as follows: 1. The Order of the Learned CIT(A) is opposed to law and facts of the case 2. The CIT(A) erred in deleting the addition of Rs.2

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

250 of the Act. 2. In first three appeals, the grounds are common except figures. Hence, we extract the grounds raised by the revenue in ITA No.1163/Bang/2024 as follows: 1. The Order of the Learned CIT(A) is opposed to law and facts of the case 2. The CIT(A) erred in deleting the addition of Rs.2

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

In the result, appeal of the assessee in ITA

Bench: Shri Chandra Poojari & Shri Keshav Dubey

250 of the Act. 2. In first three appeals, the grounds are common except figures. Hence, we extract the grounds raised by the revenue in ITA No.1163/Bang/2024 as follows: 1. The Order of the Learned CIT(A) is opposed to law and facts of the case 2. The CIT(A) erred in deleting the addition of Rs.2

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

250 of the Act. 2. In first three appeals, the grounds are common except figures. Hence, we extract the grounds raised by the revenue in ITA No.1163/Bang/2024 as follows: 1. The Order of the Learned CIT(A) is opposed to law and facts of the case 2. The CIT(A) erred in deleting the addition of Rs.2

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

250 of the Act. 2. In first three appeals, the grounds are common except figures. Hence, we extract the grounds raised by the revenue in ITA No.1163/Bang/2024 as follows: 1. The Order of the Learned CIT(A) is opposed to law and facts of the case 2. The CIT(A) erred in deleting the addition of Rs.2

MR. NATESHAN SAMPATH,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-3(1)(1), BANGALORE

In the result, appeal filed by the assessee is allowed

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year: 2018-19

250 of the Income Tax Act, 1961 (in short “The Act”) for the AY 2018-19. 2. The assessee has raised following grounds of appeal: Mr. Nateshan Sampath, Bangalore Page 2 of 12 3. Brief facts of the case are that assessee being an individual had not filed his return of income for the assessment year 2018-19. The case

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.\nThe CIT(A) has distinguished the facts\nof the case from Karnataka HC's\nruling in Manjunatha Cotton &\nGinning Factory [2013] 35\nTaxmann.com 250 (Karnataka HC)\nThe CIT(A) has concluded that the\nprovisions of 270A(8) need not be\ninvoked and that the case of the\nAssessee is covered under section\n270A

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.\nThe CIT(A) has distinguished the facts\nof the case from Karnataka HC's\nruling in Manjunatha Cotton &\nGinning Factory [2013] 35\nTaxmann.com 250 (Karnataka HC)\nThe CIT(A) has concluded that the\nprovisions of 270A(8) need not be\ninvoked and that the case of the\nAssessee is covered under section\n270A

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.\nThe CIT(A) has distinguished the facts\nof the case from Karnataka HC's\nruling in Manjunatha Cotton &\nGinning Factory [2013] 35\nTaxmann.com 250 (Karnataka HC)\nThe CIT(A) has concluded that the\nprovisions of 270A(8) need not be\ninvoked and that the case of the\nAssessee is covered under section\n270A

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.\nThe CIT(A) has distinguished the facts\nof the case from Karnataka HC's\nruling in Manjunatha Cotton &\nGinning Factory [2013] 35\nTaxmann.com 250 (Karnataka HC)\nThe CIT(A) has concluded that the\nprovisions of 270A(8) need not be\ninvoked and that the case of the\nAssessee is covered under section\n270A

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.\nThe CIT(A) has distinguished the facts\nof the case from Karnataka HC's\nruling in Manjunatha Cotton &\nGinning Factory [2013] 35\nTaxmann.com 250 (Karnataka HC)\nThe CIT(A) has concluded that the\nprovisions of 270A(8) need not be\ninvoked and that the case of the\nAssessee is covered under section\n270A

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.\nThe CIT(A) has distinguished the facts\nof the case from Karnataka HC's\nruling in Manjunatha Cotton &\nGinning Factory [2013] 35\nTaxmann.com 250 (Karnataka HC)\nThe CIT(A) has concluded that the\nprovisions of 270A(8) need not be\ninvoked and that the case of the\nAssessee is covered under section\n270A

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.\nThe CIT(A) has distinguished the facts\nof the case from Karnataka HC's\nruling in Manjunatha Cotton &\nGinning Factory [2013] 35\nTaxmann.com 250 (Karnataka HC)\nThe CIT(A) has concluded that the\nprovisions of 270A(8) need not be\ninvoked and that the case of the\nAssessee is covered under section\n270A