Navin Jindal v. Assistant Commissioner of Income Tax

Isc Speciality Chemicals LLP, Mumbai vs. ITO Ward 19(1)(5), Mumbai

In the result the appeal filed by the assessee stands partly allowed

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

…1 IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) AND SHRI GIRISH AGRAWAL (ACCOUNTANT MEMBER) I.T.A. No.457/Mum/2025 Assessment Year: 2018-19 ISC Specialty Vs Income Tax Officer, Chemicals LLP National e-Assessment 101, Atlanta, 209, Centre, Delhi/Incomce Tax Nariman Point, Officer, Ward 19(1)(5), Mumbai 400006 Mumbai National e-Assessment Centre, Delhi Piramal Chambers, Lalbaug, Mumbai PAN: AAGF17779A 400012 (Appellant) (Respondent) Appellant by Shri. Dharan Gandhi Respondent by Mr. R.A. Dhyani, CIT DR Date of Hearing 5.03.2025 Date of Pronouncement 28.05.…

Vanguard Total International Stock Index Fund, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation)-4(3)(1), Mumbai

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

…12. In support of the contention that rights entitlement are different from the shares, Ld. Counsel for the assessee had strongly placed reliance on the judgment of the Hon'ble Supreme Court in the case of Navin Jindal v. Assistant Commissioner of Income Tax[187 Taxmann 283 [2010], wherein it was held as under:- “The right to subscribe to additional offer of shares/debentures on right basis on the strength of existing shareholding in the company comes into existence when the company decides to come out with the rights offer. Prior to that, such right, though embedded in the original shareholding, yet remains inc…

Vanguard Total World Stock Index Fund, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation)-4(3)(1), Mumbai

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

…12. In support of the contention that rights entitlement are different from the shares, Ld. Counsel for the assessee had strongly placed reliance on the judgment of the Hon'ble Supreme Court in the case of Navin Jindal v. Assistant Commissioner of Income Tax[187 Taxmann 283 [2010], wherein it was held as under:- “The right to subscribe to additional offer of shares/debentures on right basis on the strength of existing shareholding in the company comes into existence when the company decides to come out with the rights offer. Prior to that, such right, though embedded in the original shareholding, yet remains inc…

Vanguard Emerging Markets Stock Index Fund A Series of Vief, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation)-4(3)(1), Mumbai

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

…12. In support of the contention that rights entitlement are different from the shares, Ld. Counsel for the assessee had strongly placed reliance on the judgment of the Hon‟ble Supreme Court in the case of Navin Jindal v. Assistant Commissioner of Income Tax[187 Taxmann 283 [2010], wherein it was held as under:- “The right to subscribe to additional offer of shares/debentures on right basis on the strength of existing shareholding in the company comes into existence when the company decides to come out with the rights offer. Prior to that, such right, though embedded in the original shareholding, yet remains inc…

Vftc Institutional Total International Stock Market Index Trust II, Mumbai vs. Assistant Commissioner of Income Tax (International Taxation)-4(3)(1), Mumbai

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

…12. In support of the contention that rights entitlement are different from the shares, Ld. Counsel for the assessee had strongly placed reliance on the judgment of the Hon'ble Supreme Court in the case of Navin Jindal v. Assistant Commissioner of Income Tax[187 Taxmann 283 [2010], wherein it was held as under:- “The right to subscribe to additional offer of shares/debentures on right basis on the strength of existing shareholding in the company comes into existence when the company decides to come out with the rights offer. Prior to that, such right, though embedded in the original shareholding, yet remains in…

Vanguard Emerging Markets Stock Index Fund A Series of vs. Plc, Mumbaivs.Assistant Commissioner of Income Tax International Taxation -4(3)(1), Mumbai

Bench: Ms Padmavathy S, Am & Shri Rahul Chaudhary, Jm

…12. In support of the contention that rights entitlement are different from the shares, Ld. Counsel for the assessee had strongly placed reliance on the judgment of the Hon‟ble Supreme Court in the case of Navin Jindal v. Assistant Commissioner of Income Tax[187 Taxmann 283 [2010], wherein it was held as under:- “The right to subscribe to additional offer of shares/debentures on right basis on the strength of existing shareholding in the company comes into existence when the company decides to come out with the rights offer. Prior to that, such right, though embedded in the original shareholding, yet remains inc…

Vanguard Emerging Markets Stock Index Fund A Series of Visplc, Mumbai vs. ACIT (International Tax)-4(3)(1), Mumbai

In the result, appeal of the assessee is allowed

Bench: SHRI AMIT SHUKLA (Judicial Member), MS PADMAVATHY S (Accountant Member)

…12. In support of the contention that rights entitlement are different from the shares, Ld. Counsel for the assessee had strongly placed reliance on the judgment of the Hon‟ble Supreme Court in the case of Navin Jindal v. Assistant Commissioner of Income Tax[187 Taxmann 283 [2010], wherein it was held as under:- “The right to subscribe to additional offer of shares/debentures on right basis on the strength of existing shareholding in the company comes into existence when the company decides to come out with the rights offer. Prior to that, such right, though embedded in the original shareholding, yet remains inc…