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

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

3)The amount of under-reported income shall be,— (i)in a case where income has been assessed for the first time,— (a)if return has been furnished, the difference between the amount of income assessed and the amount of income determined under clause (a) of sub-section (1) of section 143; (b)in a case where no return

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

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

270A and initiation of\nproceedings under section 276C of section 276CC, if he fulfils the following\nconditions, namely:—\n(a) the tax and interest payable as per the order of assessment or reassessment\nunder sub-section (3

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 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 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

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

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 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

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 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

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 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

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 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