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

B: 271(1)(c) case where original return under section 139(1) of the Act was not filed and receipts were offered to tax during the reassessment proceedings Observation of the CIT(A) Rebuttal to the CIT(A)’s observations - - The CIT(A) has held that there could Reliance placed by Delhi HC in case of be situations of overlap

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

B: 271(1)(c) case where original return under section 139(1) of the Act was not filed and receipts were offered to tax during the reassessment proceedings Observation of the CIT(A) Rebuttal to the CIT(A)’s observations - - The CIT(A) has held that there could Reliance placed by Delhi HC in case of be situations of overlap

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

B: 271(1)(c) case where original return under section 139(1) of the Act was not filed and receipts were offered to tax during the reassessment proceedings Observation of the CIT(A) Rebuttal to the CIT(A)’s observations - - The CIT(A) has held that there could Reliance placed by Delhi HC in case of be situations of overlap

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

B: 271(1)(c) case where original return under section 139(1) of the Act was not filed and receipts were offered to tax during the reassessment proceedings Observation of the CIT(A) Rebuttal to the CIT(A)’s observations - - The CIT(A) has held that there could Reliance placed by Delhi HC in case of be situations of overlap

M/S. KARNATAKA BANK LIMITED,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX. CIRCLE- 2(1), MANGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

reassess under Section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under Section 154, for any assessment year beginning on or before the 1st day of April 2001. 9. From perusal of Section 14A of the Act, it is evident that for the purposes of computing

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), MANGALORE vs. KARNATAKA BANK LIMITED., MANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

reassess under Section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under Section 154, for any assessment year beginning on or before the 1st day of April 2001. 9. From perusal of Section 14A of the Act, it is evident that for the purposes of computing

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

B: 271(1)(c) case where original return under section\n139(1) of the Act was not filed and receipts were offered to tax during the\nreassessment proceedings\nObservation of the CIT(A)\nThe CIT(A) has held that there could\nbe situations of overlap between\n'concealment of particulars income\nand inaccurate particulars of income'\nThe CIT(A) placed

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

B: 271(1)(c) case where original return under section\n139(1) of the Act was not filed and receipts were offered to tax during the\nreassessment proceedings\nPage 30 of 56\nIT(IT)A Nos.487 to 504/Bang/2024 &\nIT(IT)A Nos.541 to 546/Bang/2024\nIBM Canada Limited & Others\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations

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

B: 271(1)(c) case where original return under section\n139(1) of the Act was not filed and receipts were offered to tax during the\nreassessment proceedings\nObservation of the CIT(A)\nThe CIT(A) has held that there could\nbe situations of overlap between\n'concealment of particulars income\nand inaccurate particulars of income'\nThe CIT(A) placed

IBM DEUTSCHLAND GMBH,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

B: 271(1)(c) case where original return under section\n139(1) of the Act was not filed and receipts were offered to tax during the\nreassessment proceedings\nObservation of the CIT(A)\nThe CIT(A) has held that there could\nbe situations of overlap between\n'concealment of particulars income\nand inaccurate particulars of income'\nThe CIT(A) placed

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

B: 271(1)(c) case where original return under section\n139(1) of the Act was not filed and receipts were offered to tax during the\nreassessment proceedings\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\nThe CIT(A) has held that there could\nbe situations of overlap between\n'concealment of particulars income\nand inaccurate

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

In the result, appeal of the revenue in ITA No

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessmentyear: 2017-18

reassess under Section 147 or pass an order enhancing the assessment or reducing a refund already made or otherwise increasing the liability of the assessee under Section 154, for any assessment year beginning on or before the 1st day of April 2001. 9. From perusal of Section 14A of the Act, it is evident that for the purposes of computing

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

B: 271(1)(c) case where original return under section\n139(1) of the Act was not filed and receipts were offered to tax during the\nreassessment proceedings\nObservation of the CIT(A)\nThe CIT(A) has held that there could\nbe situations of overlap between\n'concealment of particulars income\nand inaccurate particulars of income'\nThe CIT(A) placed

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

B: 271(1)(c) case where original return under section\n139(1) of the Act was not filed and receipts were offered to tax during the\nreassessment proceedings\nObservation of the CIT(A)\nThe CIT(A) has held that there could\nbe situations of overlap between\n'concealment of particulars income\nand inaccurate particulars of income'\nThe CIT(A) placed

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

B: 271(1)(c) case where original return under section\n139(1) of the Act was not filed and receipts were offered to tax during the\nreassessment proceedings\nObservation of the CIT(A)\nThe CIT(A) has held that there could\nbe situations of overlap between\n'concealment of particulars income\nand inaccurate particulars of income'\nThe CIT(A) placed

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

B: 271(1)(c) case where original return under section\n139(1) of the Act was not filed and receipts were offered to tax during the\nreassessment proceedings\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\nThe CIT(A) has held that there could\nbe situations of overlap between\n'concealment of particulars income\nand inaccurate

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

B: 271(1)(c) case where original return under section\n139(1) of the Act was not filed and receipts were offered to tax during the\nreassessment proceedings\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\nalso have a bearing on the interpretation\nof section 271(1)(c) of the Act.\nThe CIT(A) has held

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

B: 271(1)(c) case where original return under section\n139(1) of the Act was not filed and receipts were offered to tax during the\nreassessment proceedings\n\nObservation of the CIT(A)\nRebuttal to the CIT(A)'s observations\n\nThe CIT(A) has held that there could\nbe situations of overlap between\n'concealment of particulars income

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

B: 271(1)(c) case where original return under section\n139(1) of the Act was not filed and receipts were offered to tax during the\nreassessment proceedings\nObservation of the CIT(A)\nThe CIT(A) has held that there could\nbe situations of overlap between\n'concealment of particulars income\nand inaccurate particulars of income'\nThe CIT(A) placed