An IBM spokesperson told FE in reply to an email, IBM does not agree with the tax departments claims and will aggressively defend itself through the appropriate judicial process.
IBMs appeal before DRP is without any prejudice to its right for any other legal action that the company may pursue. The tax demand apparently pertains to 2006-07 fiscal. IBM, however, did not comment on the specifics of the tax demand such as the amount or the year it pertains to.
IBM has extensive presence in India and is engaged in software development, outsourcing and research.