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 orders under section 143(3) read with section 147 of the Act/ assessment order under section 143(3) of the Act were issued along with show- cause notices for imposing penalty under section 271(1)(c) of the Act for the matters pertaining to AY 2012-13 to AY 2016-17 and 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 orders under section 143(3) read with section 147 of the Act/ assessment order under section 143(3) of the Act were issued along with show- cause notices for imposing penalty under section 271(1)(c) of the Act for the matters pertaining to AY 2012-13 to AY 2016-17 and 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 orders under section 143(3) read with section 147 of the Act/ assessment order under section 143(3) of the Act were issued along with show- cause notices for imposing penalty under section 271(1)(c) of the Act for the matters pertaining to AY 2012-13 to AY 2016-17 and under section 270A

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 orders under section 143(3) read with section 147 of the Act/ assessment order under section 143(3) of the Act were issued along with show- cause notices for imposing penalty under section 271(1)(c) of the Act for the matters pertaining to AY 2012-13 to AY 2016-17 and under section 270A

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

reassessment, referred to in\nclause (a) of sub-section (1), in a case where an order under sub-section (4) has\nbeen made accepting the application.”\n5.3 Before leaping to section 270A

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

The appeals of the assessees are allowed

reassessment orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1)(c) of the Act\nfor the matters pertaining to AY 2012-13 to AY 2016-17 and under\nsection 270A

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 orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1)(c) of the Act\nfor the matters pertaining to AY 2012-13 to AY 2016-17 and under\nsection 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

reassessment orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1)(c) of the Act\nfor the matters pertaining to AY 2012-13 to AY 2016-17 and under\nsection 270A

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 orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1)(c) of the Act\nfor the matters pertaining to AY 2012-13 to AY 2016-17 and under\nsection 270A

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 orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1)(c) of the Act\nfor the matters pertaining to AY 2012-13 to AY 2016-17 and under\nsection 270A

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 orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1)(c) of the Act\nfor the matters pertaining to AY 2012-13 to AY 2016-17 and under\nsection 270A

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 orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1)(c) of the Act\nfor the matters pertaining to AY 2012-13 to AY 2016-17 and under\nsection 270A

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

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 orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1)(c) of the Act\nfor the matters pertaining to AY 2012-13 to AY 2016-17 and under\nsection 270A

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

The appeals of the assessees are allowed

reassessment orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1)(c) of the Act\nfor the matters pertaining to AY 2012-13 to AY 2016-17 and under\nsection 270A

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 orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1)(c) of the Act\nfor the matters pertaining to AY 2012-13 to AY 2016-17 and under\nsection 270A

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 orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1)(c) of the Act\nfor the matters pertaining to AY 2012-13 to AY 2016-17 and under\nsection 270A

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 orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1)(c) of the Act\nfor the matters pertaining to AY 2012-13 to AY 2016-17 and under\nsection 270A

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

reassessment orders\nunder section 143(3) read with section 147 of the Act/assessment\norder under section 143(3) of the Act were issued along with show-\ncause notices for imposing penalty under section 271(1)(c) of the Act\nfor the matters pertaining to AY 2012-13 to AY 2016-17 and under\nsection 270A