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

u/s 273B was applied ‘reasonable cause’ under section 273B of based on the facts of that case. the Act. - The reference to the above case by the (Page 17-18 of the CIT(A) order) Assessee was only in the context of the principle emanating from the same which could also be used in the context of section 270A

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

u/s 273B was applied ‘reasonable cause’ under section 273B of based on the facts of that case. the Act. - The reference to the above case by the (Page 17-18 of the CIT(A) order) Assessee was only in the context of the principle emanating from the same which could also be used in the context of section 270A

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

Bench: Shri Chandra Poojari & Smt. Beena Pillai

147 of the Act; 4.5.5 Assuming but not admitting, in case of conflicting rulings, the Assessee is entitled to place reliance on rulings favorable to him and ought not to be penalized for adopting a favourable view in the said issue. Relevant judicial precedents were discussed to justify that non-acceptance of the bonafide explanation offered by the Assessee

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

147 of the Act; 4.5.5 Assuming but not admitting, in case of conflicting rulings, the Assessee is entitled to place reliance on rulings favorable to him and ought not to be penalized for adopting a favourable view in the said issue. Relevant judicial precedents were discussed to justify that non-acceptance of the bonafide explanation offered by the Assessee

SRI. PANATI VIKRAMDEVA REDDY,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1), BENGALURU

In the result, the appeals of the assessee are dismissed

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahu

147 r.w.s. 144B of the Act. 4. Penalty proceedings u/s. 274 r.w.s. 271(1)(b) were also initiated by show cause notice dated 28.03.2022. Another show cause notice dated 26.8.2022 was issued to upload submission as per mandate of Faceless Penalty Scheme and that penalty initiated u/s. 271(1)(b) being a technical penalty it cannot be kept in abeyance

SRI. PANATI VIKRAMDEVA REDDY,,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1), BENGALURU

In the result, the appeals of the assessee are dismissed

Bench: Shri Narender Kumar Choudhry & Shri Laxmi Prasad Sahu

147 r.w.s. 144B of the Act. 4. Penalty proceedings u/s. 274 r.w.s. 271(1)(b) were also initiated by show cause notice dated 28.03.2022. Another show cause notice dated 26.8.2022 was issued to upload submission as per mandate of Faceless Penalty Scheme and that penalty initiated u/s. 271(1)(b) being a technical penalty it cannot be kept in abeyance

M/S HUBLI DHARWAD STOCK TRADING HOUSE ,HUBLI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-1(1), HUBLI

In the result, the assessee's appeals for Assessment Years 1997-98,

Bench: Shri George George K & Shri Jason P Boaz

u/s 271(1)(c) of the Act require no adjudication by us at this stage. 5. In the result, assessee’s appeals for asst. year 1997-98, 2000-01 to 2002-03, 2004-05 and 2005-06 are allowed as indicated above. 6. Assessee's appeals in ITA Nos.891, 893, 895, 897, 899 and 902/Bang/2017. 6.1 These are six appeals

SRI. GANGASHARA SHETTY, ,DAKSHINA KANNADA vs. INCOME TAX OFFICER, WARD-2(1), MANGALORE

In the result, appeal of the assessee stands allowed

Bench: Ms. Padmavathy S. & Shri Prakash Chand Yadavassessment Year: 2017-18

147 of the Act. The assessee has been asked to Sri Gangadhara Shetty, Mangalore Page 2 of 5 file the true and correct affairs of his income. In response, the assessee submitted his return of income declaring total income as Nil. During the course of assessment proceedings, the AO observed that the assessee has earned long term capital gain amounting