M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

251 and settled principle that the duty of\nthe Appellate Authority is to remove the defects or\nirregularities that occur in the course of the\nassessment proceeding.\n13. As regards addition of Rs. 1,55,45,376/- on\naccount purchase of tendu leaves;\n13.1. The impugned addition of Rs. Rs. 1,55,45,376/-\ntowards account purchase of tendu leaves

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

2 Karl Storz Endoscopy India Favourable Delhi HC 13 September (P) Limited (ITA No 13 of 2010 2008) (Delhi HC) (refer page 199 – 201 of PB) 3 Abbey Business Services Favourable Bangalore 18 July 2012 India Pvt Ltd (23 ITAT Taxmann.com 346) – later on confirmed by Karnataka High Court 4 Marks & Spencer Reliance Favourable Mumbai 4 September India Private Limited

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

2 Karl Storz Endoscopy India Favourable Delhi HC 13 September (P) Limited (ITA No 13 of 2010 2008) (Delhi HC) (refer page 199 – 201 of PB) 3 Abbey Business Services Favourable Bangalore 18 July 2012 India Pvt Ltd (23 ITAT Taxmann.com 346) – later on confirmed by Karnataka High Court 4 Marks & Spencer Reliance Favourable Mumbai 4 September India Private Limited

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

2 Karl Storz Endoscopy India Favourable Delhi HC 13 September (P) Limited (ITA No 13 of 2010 2008) (Delhi HC) (refer page 199 – 201 of PB) 3 Abbey Business Services Favourable Bangalore 18 July 2012 India Pvt Ltd (23 ITAT Taxmann.com 346) – later on confirmed by Karnataka High Court 4 Marks & Spencer Reliance Favourable Mumbai 4 September India Private Limited

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

2 Karl Storz Endoscopy India Favourable Delhi HC 13 September (P) Limited (ITA No 13 of 2010 2008) (Delhi HC) (refer page 199 – 201 of PB) 3 Abbey Business Services Favourable Bangalore 18 July 2012 India Pvt Ltd (23 ITAT Taxmann.com 346) – later on confirmed by Karnataka High Court 4 Marks & Spencer Reliance Favourable Mumbai 4 September India Private Limited

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

2)\nof the Act on 3 August 2012 in respect of Rol filed for AY 2011-12. It\nis in the said assessment for the AY 2011-12 that the issue of\ntaxation of secondment reimbursements was first scrutinized\nthreadbare. After a thorough analysis of this issue, an amount of\nRs 83,49,00,000 was accepted

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

2)\nof the Act on 3 August 2012 in respect of Rol filed for AY 2011-12. It\nis in the said assessment for the AY 2011-12 that the issue of\ntaxation of secondment reimbursements was first scrutinized\nthreadbare. After a thorough analysis of this issue, an amount of\nRs 83,49,00,000 was accepted

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

2)\nof the Act on 3 August 2012 in respect of Rol filed for AY 2011-12. It\nis in the said assessment for the AY 2011-12 that the issue of\ntaxation of secondment reimbursements was first scrutinized\nthreadbare. After a thorough analysis of this issue, an amount of\nRs 83,49,00,000 was accepted

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

2)\nof the Act on 3 August 2012 in respect of Rol filed for AY 2011-12. It\nis in the said assessment for the AY 2011-12 that the issue of\ntaxation of secondment reimbursements was first scrutinized\nthreadbare. After a thorough analysis of this issue, an amount of\nRs 83,49,00,000 was accepted

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

2)\nof the Act on 3 August 2012 in respect of Rol filed for AY 2011-12. It\nis in the said assessment for the AY 2011-12 that the issue of\ntaxation of secondment reimbursements was first scrutinized\nthreadbare. After a thorough analysis of this issue, an amount of\nRs 83,49,00,000 was accepted

M/S. BHARAT BEEDI WORKS PRIVATE LIMITED,MANGALURU vs. DEPUTY COMMISIONER OF INCOME TAX, CENTRAL CIRCLE - 2, MANGALURU

In the result, all the appeals filed by the assessee are allowed

251 and settled principle that the duty of\nthe Appellate Authority is to remove the defects or\nirregularities that occur in the course of the\nassessment proceeding.\n\n13. As regards addition of Rs.1,55,45,376/- on\naccount purchase of tendu leaves;\n\n13. 1. The impugned addition of Rs. Rs.1,55,45,376/-\ntowards account purchase of tendu

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

2)\nof the Act on 3 August 2012 in respect of Rol filed for AY 2011-12. It\nis in the said assessment for the AY 2011-12 that the issue of\ntaxation of secondment reimbursements was first scrutinized\nthreadbare. After a thorough analysis of this issue, an amount of\nRs 83,49,00,000 was accepted

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

2)\nof the Act on 3 August 2012 in respect of Rol filed for AY 2011-12. It\nis in the said assessment for the AY 2011-12 that the issue of\ntaxation of secondment reimbursements was first scrutinized\nthreadbare. After a thorough analysis of this issue, an amount of\nRs 83,49,00,000 was accepted

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

The appeals of the assessees are allowed

2)\nof the Act on 3 August 2012 in respect of Rol filed for AY 2011-12. It\nis in the said assessment for the AY 2011-12 that the issue of\ntaxation of secondment reimbursements was first scrutinized\nthreadbare. After a thorough analysis of this issue, an amount of\nRs 83,49,00,000 was accepted

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

2)\nof the Act on 3 August 2012 in respect of Rol filed for AY 2011-12. It\nis in the said assessment for the AY 2011-12 that the issue of\ntaxation of secondment reimbursements was first scrutinized\nthreadbare. After a thorough analysis of this issue, an amount of\nRs 83,49,00,000 was accepted

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

2)\nof the Act on 3 August 2012 in respect of Rol filed for AY 2011-12. It\nis in the said assessment for the AY 2011-12 that the issue of\ntaxation of secondment reimbursements was first scrutinized\nthreadbare. After a thorough analysis of this issue, an amount of\nRs 83,49,00,000 was accepted

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

2)\nof the Act on 3 August 2012 in respect of Rol filed for AY 2011-12. It\nis in the said assessment for the AY 2011-12 that the issue of\ntaxation of secondment reimbursements was first scrutinized\nthreadbare. After a thorough analysis of this issue, an amount of\nRs 83,49,00,000 was accepted

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

2)\nof the Act on 3 August 2012 in respect of Rol filed for AY 2011-12. It\nis in the said assessment for the AY 2011-12 that the issue of\ntaxation of secondment reimbursements was first scrutinized\nthreadbare. After a thorough analysis of this issue, an amount of\nRs 83,49,00,000 was accepted