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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

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

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

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

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

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

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

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

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

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

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

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

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

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

Bench: Shri Chandra Poojari & Smt. Beena Pillaiit(It)A Nos.490 & 491/Bang/2024

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

SRI DEEPAK S HIREMATH, HUBBALI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), HUBBALI

In the result, the assessee’s appeals for Assessment Years 2008-09 to 2012-13 are allowed

Bench: Shri N. V. Vasudevan & Shri Jason P. Boaz

1)(c), i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. q) Sending printed form where all the ground mentioned in Section 271 are mentioned would not satisfy requirement of law. r) The assessee should know the grounds which he has to meet specifically. Otherwise, principles of natural justice is offended

SRI DEEPAK S HIREMATH ,HUBBALLI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), HUBBALLI

In the result, the assessee’s appeals for Assessment Years 2008-09 to 2012-13 are allowed

Bench: Shri N. V. Vasudevan & Shri Jason P. Boaz

1)(c), i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. q) Sending printed form where all the ground mentioned in Section 271 are mentioned would not satisfy requirement of law. r) The assessee should know the grounds which he has to meet specifically. Otherwise, principles of natural justice is offended

SRI DEEPAK S HIREMATH ,HUBALI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), HUBLI

In the result, the assessee’s appeals for Assessment Years 2008-09 to 2012-13 are allowed

Bench: Shri N. V. Vasudevan & Shri Jason P. Boaz

1)(c), i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. q) Sending printed form where all the ground mentioned in Section 271 are mentioned would not satisfy requirement of law. r) The assessee should know the grounds which he has to meet specifically. Otherwise, principles of natural justice is offended

SRI DEEPAK S HIREMATH ,HUBBALI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), HUBBLI

In the result, the assessee’s appeals for Assessment Years 2008-09 to 2012-13 are allowed

Bench: Shri N. V. Vasudevan & Shri Jason P. Boaz

1)(c), i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. q) Sending printed form where all the ground mentioned in Section 271 are mentioned would not satisfy requirement of law. r) The assessee should know the grounds which he has to meet specifically. Otherwise, principles of natural justice is offended

SRI DEEPAK S HIREMATH, HUBBALI vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), HUBBALI

In the result, the assessee’s appeals for Assessment Years 2008-09 to 2012-13 are allowed

Bench: Shri N. V. Vasudevan & Shri Jason P. Boaz

1)(c), i.e., whether it is for concealment of income or for furnishing of incorrect particulars of income. q) Sending printed form where all the ground mentioned in Section 271 are mentioned would not satisfy requirement of law. r) The assessee should know the grounds which he has to meet specifically. Otherwise, principles of natural justice is offended

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

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