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
ITA 496/BANG/2024[2016-17]Status: DisposedITAT Bangalore20 May 2024AY 2016-17
Bench: Shri Chandra Poojari & Smt. Beena Pillai
section 197, in respect to deductibility of tax on similar receipts
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The CIT(A) highlighted that section 195(2) and section 197 of the Act are in the nature of safeguard sections to make sure that taxes are rightfully deducted on payments.
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The CIT(A) has thereafter contended that the Assessee has not availed any of the safeguards and basis
