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 of the Act, we first consider\nsection 270AA of the Act in order to find out whether the Form 68\nfiled by the Assessee Company on 06/10/2022

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

E: 270A case where original return under section 139(1) of the Act has not been filed and receipts were offered to tax in the return filed under section 148 of the Act IBM Canada Limited 2017- 270A 543/Bang/2024 Not filed In ROI filed 18 u/s 148 Category F: 270A case where original return under section

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

E: 270A case where original return under section 139(1) of the Act has not been filed and receipts were offered to tax in the return filed under section 148 of the Act IBM Canada Limited 2017- 270A 543/Bang/2024 Not filed In ROI filed 18 u/s 148 Category F: 270A case where original return under section

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

E: 270A case where original return under section 139(1) of the Act has not been filed and receipts were offered to tax in the return filed under section 148 of the Act IBM Canada Limited 2017- 270A 543/Bang/2024 Not filed In ROI filed 18 u/s 148 Category F: 270A case where original return under section

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

E: 270A case where original return under section 139(1) of the Act has not been filed and receipts were offered to tax in the return filed under section 148 of the Act IBM Canada Limited 2017- 270A 543/Bang/2024 Not filed In ROI filed 18 u/s 148 Category F: 270A case where original return under section

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

9)The cases of misreporting of income referred to in sub-section (8) shall be the following, namely:— (a)misrepresentation or suppression of facts; (b)failure to record investments in the books of account; (c)claim of expenditure not substantiated by any evidence; (d)recording of any false entry in the books of account; Dcit(E), Circle-1, Bengaluru Page

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

E: 270A case where original return under section 139(1) of the Act has not\nbeen filed and receipts were offered to tax in the return filed under section 148 of the\nAct\nIBM Canada Limited\n2017-\n270A\n543/Bang/2024\nNot filed\nIn ROI filed\n18\nu/s 148\nCategory F: 270A case where original return 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

E: 270A case where original return under section 139(1) of the Act has not\nbeen filed and receipts were offered to tax in the return filed under section 148 of the\nAct\nIBM Canada Limited\n2017-\n270A\n543/Bang/2024\nNot filed\nIn ROI filed\n18\nu/s 148\nCategory F: 270A case where original return under section

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

E: 270A case where original return under section 139(1) of the Act has not\nbeen filed and receipts were offered to tax in the return filed under section 148 of the\nAct\nIBM Canada Limited\n2017-\n270A\n543/Bang/2024\nNot filed\nIn ROI filed\n18\nu/s 148\nCategory F: 270A case where original return under section

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

E: 270A case where original return under section 139(1) of the Act has not\nbeen filed and receipts were offered to tax in the return filed under section 148 of the\nAct\nIBM Canada Limited\n2017-\n270A\n543/Bang/2024\nNot filed\nIn ROI filed\n18\nu/s 148\nCategory F: 270A case where original return 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

E: 270A case where original return under section 139(1) of the Act has not\nbeen filed and receipts were offered to tax in the return filed under section 148 of the\nAct\nIBM Canada Limited\n2017-\n270A\n543/Bang/2024\nNot filed\nIn ROI filed\n18\nu/s 148\nCategory F: 270A case where original return 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

E: 270A case where original return under section 139(1) of the Act has not\nbeen filed and receipts were offered to tax in the return filed under section 148 of the\nAct\nIBM Canada Limited\n2017-\n270A\n543/Bang/2024\nNot filed\nIn ROI filed\n18\nu/s 148\nCategory F: 270A case where original return 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

E: 270A case where original return under section 139(1) of the Act has not\nbeen filed and receipts were offered to tax in the return filed under section 148 of the\nAct\nIBM Canada Limited\n2017-\n270A\n543/Bang/2024\nNot filed\nIn ROI filed\n18\nu/s 148\nCategory F: 270A case where original return under section

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

E: 270A case where original return under section 139(1) of the Act has not\nbeen filed and receipts were offered to tax in the return filed under section 148 of the\nAct\nIBM Canada Limited\n2017-\n270A\n543/Bang/2024\nNot filed\nIn ROI filed\nu/s 148\n18\nCategory F: 270A case where original return 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

E: 270A case where original return under section 139(1) of the Act has not\nbeen filed and receipts were offered to tax in the return filed under section 148 of the\nAct\nIBM Canada Limited\n2017-\n270A\n543/Bang/2024\nNot filed\nIn ROI filed\n18\nu/s 148\nCategory F: 270A case where original return 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

E: 270A case where original return under section 139(1) of the Act has not\nbeen filed and receipts were offered to tax in the return filed under section 148 of the\nAct\nIBM Canada Limited\n2017-\n270A\n543/Bang/2024 Not filed\nIn ROI filed\n18\nu/s 148\nCategory F: 270A case where original return under section

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

E: 270A case where original return under section 139(1) of the Act has not\nbeen filed and receipts were offered to tax in the return filed under section 148 of the\nAct\nIBM Canada Limited\n2017-\n270A\n543/Bang/2024 | Not filed\nIn ROI filed\n18\nu/s 148\nCategory F: 270A case where original return under section

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

E: 270A case where original return under section 139(1) of the Act has not\nbeen filed and receipts were offered to tax in the return filed under section 148 of the\nAct\nIBM Canada Limited\n2017-\n18\n270A\n543/Bang/2024\nNot filed\nIn ROI filed\nu/s 148\nCategory F: 270A case where original return under section

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

E: 270A case where original return under section 139(1) of the Act has not\nbeen filed and receipts were offered to tax in the return filed under section 148 of the\nAct\n\nIBM Canada Limited\n2017-\n270A\n543/Bang/2024 Not filed\nIn ROI filed\n18\nu/s 148\nCategory F: 270A case where original return under section