Taxability of secondment receipts: ITAT deletes Section 271(1)(c) & 270A Penalty

IBM Canada Limited Vs DCIT (International Taxation) (ITAT Bangalore)

In the case of IBM Canada Limited vs. DCIT (International Taxation) heard at ITAT Bangalore, the issue at hand revolved around the imposition of penalties under sections 271(1)(c) and 270A of the Income Tax Act (ITA) in various assessment years. The penalties fell into different categories based on the circumstances under which they were levied.

Category ‘A’ involved penalties under section 271(1)(c) where the original return under section 139(1) of the ITA had not been filed, and receipts were

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