ICICI Securities Limited v. ITO (International Taxation)

198 ITD 214Income Tax Appellate Tribunal2023#19683 most cited
4

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2025 to 2025.

Sections most often in play

Section 139Section 194CSection 201Section 201(1A)Section 195Section 38Section 201(1)

Issues it is cited on

section 38right to receivemlisection 201(1a)section 194csection 195assessee in defaultsection 201(1)advance taxtax deducted at sourcesection 201section 194

Judgments citing ICICI Securities Limited v. ITO (International Taxation)

ITO (TDS) Alwar, Alwar vs. Shri Baba Mohan Ramji Kalikholi Walamilkpur Gurjar, Alwar

9. In view of the above discussion, all the appeals filed by the department deserve to be dismissed

ITA 746/JPR/2025[2019-20]Status: DisposedITAT Jaipur02 Sept 2025AY 2019-20

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 194CSection 201(1)Section 38

…) of Rs.2,946/- is concerned, once the assessee is held as not an assessee in default, no interest for non-deduction can be levied. Reliance in this connection is placed on the following cases:- ICICI Securities Limited Vs. ITO (International Taxation) (2023) 198 ITD 214 (Mumbai) (Trib.) The facts of the case are that assessee sold 15,39,100 shares of Ranbaxy held by the ICICI Shri Baba Mohan Ramji Kalikholi Walamilkpur Gurjar, Alwar. Bank on behalf of BNY and sent the remittances aggregating to Rs.94,61,35,488/- to BNY Mellon, New York. A payment of Rs.40,92,98,212/- was made towards the tax liability of the BN…

ITO (TDS) Alwar, Alwar vs. Shri Baba Mohan Ramji Kalikholi Walamilkpur Gurjar, Alwar

9. In view of the above discussion, all the appeals filed by the department deserve to be dismissed

ITA 745/JPR/2025[2018-19]Status: DisposedITAT Jaipur02 Sept 2025AY 2018-19

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 194CSection 201(1)Section 38

…) of Rs.2,946/- is concerned, once the assessee is held as not an assessee in default, no interest for non-deduction can be levied. Reliance in this connection is placed on the following cases:- ICICI Securities Limited Vs. ITO (International Taxation) (2023) 198 ITD 214 (Mumbai) (Trib.) The facts of the case are that assessee sold 15,39,100 shares of Ranbaxy held by the ICICI Shri Baba Mohan Ramji Kalikholi Walamilkpur Gurjar, Alwar. Bank on behalf of BNY and sent the remittances aggregating to Rs.94,61,35,488/- to BNY Mellon, New York. A payment of Rs.40,92,98,212/- was made towards the tax liability of the BN…

ITO (TDS) Alwar, Alwar vs. Shri Baba Mohan Ramji Kalikholi Walamilkpur Gurjar, Alwar

9. In view of the above discussion, all the appeals filed by the department deserve to be dismissed

ITA 744/JPR/2025[2016-17]Status: DisposedITAT Jaipur02 Sept 2025AY 2016-17

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 194CSection 201(1)Section 38

…) of Rs.2,946/- is concerned, once the assessee is held as not an assessee in default, no interest for non-deduction can be levied. Reliance in this connection is placed on the following cases:- ICICI Securities Limited Vs. ITO (International Taxation) (2023) 198 ITD 214 (Mumbai) (Trib.) The facts of the case are that assessee sold 15,39,100 shares of Ranbaxy held by the ICICI Shri Baba Mohan Ramji Kalikholi Walamilkpur Gurjar, Alwar. Bank on behalf of BNY and sent the remittances aggregating to Rs.94,61,35,488/- to BNY Mellon, New York. A payment of Rs.40,92,98,212/- was made towards the tax liability of the BN…

ITO(TDS) Alwar, Alwar vs. Shri Baba Mohan Ramji Kalikholi Walamilkpur Gurjar, Alwar

9. In view of the above discussion, all the appeals filed by the department deserve to be dismissed

ITA 739/JPR/2025[2017-18]Status: DisposedITAT Jaipur02 Sept 2025AY 2017-18

Bench: SHRI GAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri P.C. Parwal, C.AFor Respondent: Shri Gautam Singh Choudhary, Addl. CIT
Section 194CSection 201(1)Section 38

…) of Rs.2,946/- is concerned, once the assessee is held as not an assessee in default, no interest for non-deduction can be levied. Reliance in this connection is placed on the following cases:- ICICI Securities Limited Vs. ITO (International Taxation) (2023) 198 ITD 214 (Mumbai) (Trib.) The facts of the case are that assessee sold 15,39,100 shares of Ranbaxy held by the ICICI Shri Baba Mohan Ramji Kalikholi Walamilkpur Gurjar, Alwar. Bank on behalf of BNY and sent the remittances aggregating to Rs.94,61,35,488/- to BNY Mellon, New York. A payment of Rs.40,92,98,212/- was made towards the tax liability of the BN…