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“International Financial Services Centre”

Chapter XII - Special RatesSection 115ACASection 115ACA Explanation / Section 2 of SEZ Act19 judgments

ASCENTECH ENGINEERING SOLUTIONS PRIVATE LIMITED,HYDERABAD vs. DCIT, CIRCLE 1(1), HYDERABAD

In the result, appeal of the Assessee is allowed

ITA 1686/HYD/2025[2017-18]Status: HeardITAT Hyderabad06 Mar 2026AY 2017-18
For Appellant: MS Sree Lekha, AdvocateFor Respondent: Sri Mathivanan S A, Sr. AR
Section 56(2)(vii)Section 56(2)(viib)

{ "clean_text": "IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A' Bench, Hyderabad\nBEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT\nAND

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

In the result, all the three appeals of the Assessee\nare partly allowed

ITA 2149/HYD/2025[2018-19]Status: DisposedITAT Hyderabad11 Feb 2026AY 2018-19
For Appellant: \nCA MV Prasad AndFor Respondent: \nMS U Mini Chandran, CIT-DR
Section 56(2)(viib)

regulated under the\n"[Inter-national Financial Services Centre Authority\n(Fund Management) Regulations, 2022 made under\nthe] International Financial Services Centres Authority\nAct, 2019 (50 of 2019)];\n24\nITA.Nos.2147, 2148 and 2149/Hyd./2025\n“Rule-11UA(2)\n[(2)\nNotwithstanding anything contained in sub-clause (b) of\nclause ... Alternative\nInvestment Fund under the Alternative Investment Funds\nRegulations [or as referred to in sub-regulation (2) of\nregulation 18 of the International Financial Services Centres\nAuthority (Fund Management) Regulations, 2022 made\nunder the International Financial Services Centres Authority\nAct, 2019 (50 of 2019),] and which fulfils the following\nconditions

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

ITA 2148/HYD/2025[2017-18]Status: DisposedITAT Hyderabad11 Feb 2026AY 2017-18
For Appellant: \nCA MV Prasad AndFor Respondent: \nMS U Mini Chandran, CIT-DR
Section 56(2)(viib)

regulated under the\n"[Inter-national Financial Services Centre Authority\n(Fund Management) Regulations, 2022 made under\nthe] International Financial Services Centres Authority\nAct, 2019 (50 of 2019)];\n23\nITA.Nos.2147, 2148 and 2149/Hyd./2025\n“Rule-11UA(2)\n[(2)\nNotwithstanding anything contained in sub-clause (b) of\nclause ... Alternative\nInvestment Fund under the Alternative Investment Funds\nRegulations [or as referred to in sub-regulation (2) of\nregulation 18 of the International Financial Services Centres\nAuthority (Fund Management) Regulations, 2022 made\nunder the International Financial Services Centres Authority\nAct, 2019 (50 of 2019),] and which fulfils the following\nconditions

DIABETOMICS MEDICAL PRIVATE LIMITED,HYDERABAD vs. ACIT, CIRCLE-8(1), HYDERABAD

ITA 2147/HYD/2025[2016-17]Status: DisposedITAT Hyderabad11 Feb 2026AY 2016-17
For Appellant: CA MV Prasad AndFor Respondent: MS U Mini Chandran, CIT-DR
Section 56(2)(viib)

regulated under the\n"[Inter-national Financial Services Centre Authority\n(Fund Management) Regulations, 2022 made under\nthe] International Financial Services Centres Authority\nAct, 2019 (50 of 2019)];\n24\nITA.Nos.2147, 2148 and 2149/Hyd./2025\n“Rule-11UA(2)\n[(2) Notwithstanding anything contained in sub-clause (b) of\nclause ... Alternative\nInvestment Fund under the Alternative Investment Funds\nRegulations [or as referred to in sub-regulation (2) of\nregulation 18 of the International Financial Services Centres\nAuthority (Fund Management) Regulations, 2022 made\nunder the International Financial Services Centres Authority\nAct, 2019 (50 of 2019),] and which fulfils the following\nconditions

VASHISHTHA LUXURY FASHION LIMITED,MUMBAI vs. DEPUTY DIRECTOR OF INCOME-TAX, CENTRALISED PROCESSING CENTER, BENGALURU,

In the result, appeal filed by the assessee is hereby allowed

ITA 1665/MUM/2025[2023-24]Status: DisposedITAT Mumbai12 Jan 2026AY 2023-24

Bench: SHRI OM PRAKASH KANT (Accountant Member), MS. KAVITHA RAJAGOPAL (Judicial Member)

For Appellant: Shri Manish Agarwal(virtually appeared)For Respondent: Shri Annavaram Kosuri, Sr. DR
Section 115BSection 119(2)(b)Section 139(1)Section 139(4)Section 143(1)Section 143(1)(a)Section 250

assessment year beginning on the 1st day of April, 2020. (4) In case of a person, having a Unit in the International Financial Services Centre, as referred to in sub-section (1A) of section 80LA, which has exercised option under sub- section (5), the conditions contained in sub-section

M/S. SAHAJANAND LASER TECHNOLOGY LTD.,,GANDHINAGAR vs. THE DCIT, CIRCLE-4(1)(1),, AHMEDABAD

In the result, the appeal of the assessee for A

ITA 16/AHD/2020[2013-14]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2013-14

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 15 & 16/Ahd/2020 (िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14)

For Appellant: Ms. Arti N Shah, ARFor Respondent: Shri Praveen Verma, CIT. DR
Section 10ASection 143(3)Section 14ASection 35

entrepreneur in a Special Economic Zone and includes an existing Unit, an Offshore Banking Unit and a Unit in an International Financial Services Centre, whether established before or established after commencement of this Act; [Emphasis supplied.] 4.7 As per this definition, any unit located in SEZ whether established before

M/S. SAHAJANAND LASER TECHNOLOGY LTD.,,GANDHINAGAR vs. THE ITO, WARD-4(1)(1),, AHMEDABAD

In the result, the appeal of the assessee for A

ITA 15/AHD/2020[2012-13]Status: DisposedITAT Ahmedabad01 Jan 2026AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. Nos. 15 & 16/Ahd/2020 (िनधा"रण वष" / Assessment Years : 2012-13 & 2013-14)

For Appellant: Ms. Arti N Shah, ARFor Respondent: Shri Praveen Verma, CIT. DR
Section 10ASection 143(3)Section 14ASection 35

entrepreneur in a Special Economic Zone and includes an existing Unit, an Offshore Banking Unit and a Unit in an International Financial Services Centre, whether established before or established after commencement of this Act; [Emphasis supplied.] 4.7 As per this definition, any unit located in SEZ whether established before

SANJU SONI,JODHPUR vs. ITO, WARD-1(1), JODHPUR

14. In view of the above findings, both the appeals deserve to be allowed

ITA 899/JODH/2024[2023-24]Status: DisposedITAT Jodhpur29 Sept 2025AY 2023-24

Bench: Dr. MITHA LAL MEENA (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Mohit Soni, AdvocateFor Respondent: Smt. Ayushi Sharma, JCIT-DR
Section 115BSection 139(4)Section 143(1)Section 250

assessment year beginning on the 1st day of April, 2021. (4) In case of a person, having a Unit in the International Financial Services Centre, as referred to in sub-section (1A) of section 80LA, which has exercised option under sub-section (5), the conditions contained in sub-section

SANJU SONI,JODHPUR vs. ITO, WARD-1(1), JODHPUR

14. In view of the above findings, both the appeals deserve to be allowed

ITA 898/JODH/2024[2022-23]Status: DisposedITAT Jodhpur29 Sept 2025AY 2022-23

Bench: Dr. MITHA LAL MEENA (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Mohit Soni, AdvocateFor Respondent: Smt. Ayushi Sharma, JCIT-DR
Section 115BSection 139(4)Section 143(1)Section 250

assessment year beginning on the 1st day of April, 2021. (4) In case of a person, having a Unit in the International Financial Services Centre, as referred to in sub-section (1A) of section 80LA, which has exercised option under sub-section (5), the conditions contained in sub-section

VINAY TARACHAND CHAWLA,MUMBAI vs. PRINCIPAL COMMISSIONER OF INCOME TAX - 6, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 3371/MUM/2025[2020-21]Status: DisposedITAT Mumbai26 Sept 2025AY 2020-21
Section 2(47)Section 263Section 36(1)(vii)

with the provisions of the regulations made under\nthe Securities and Exchange Board of India Act, 1992 (15 of\n1992) or under the International Financial Services Centres\nAuthority Act, 2019 (50 of 2019);\n55[(c) any unit linked insurance policy to which exemption under clause (10D)\nof section 10 does

GREEN INFRA WIND FARM ASSET LTD.,GURUGRAM vs. ACIT, CIRCLE 10(2), NEW DELHI

In the result, the appeal of the assessee is partly allowed

ITA 930/DEL/2020[2016-17]Status: DisposedITAT Delhi04 Jul 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal[Assessment Year : 2016-17] Green Infra Wind Farm Asset Ltd., Vs Acit, 5Th Floor, Tower C, Building No.8, Circle-10(2), Dlf Cyber City, Gurugram, New Delhi. Haryana-122002. Pan-Aaecg4080H Appellant Respondent Appellant By Shri Vartik Chokshi, Ca & Shri Biren Shah, Ca Respondent By Shri Rajesh Kumar Dhanesta, Sr.Dr Date Of Hearing 23.04.2025 Date Of Pronouncement 04.07.2025 Order

Section 115JSection 143(3)Section 250

April, 2012. (7)Notwithstanding anything contained in sub-section (1), where the assessee referred to therein, is a unit located in an International Financial Services Centre and derives its income solely in convertible foreign exchange, the provisions of sub-section (1) shall have the effect as if for the words ... wherever occurring in that sub- section, the words "nine per cent" had been substituted. Explanation.—For the purposes of this sub-section,— (a)"International Financial Services Centre" shall have the same meaning as assigned to it in clause (q) of section 2 of the Special Economic Zones

KUMAR MEDICARE PVT LTD ,MUMBAI vs. COMMISSIONER OF INCOME TAX DEPARTMENT , MUMBAI

In the result, based on above, the appeal of the assessee is partly allowed for statistical purposes

ITA 1675/MUM/2024[2020-21]Status: DisposedITAT Mumbai21 Aug 2024AY 2020-21

Bench: Shri Amit Shukla & Shri Gagan Goyalkumar Medicare Pvt. Ltd., 001 Gr. Floor, Shivashirwad Building, Ganesh Mandir Road, Dombivali East, Thane Maharashtra 421 201 Pan: Aacck4186G ..... Appellant Vs. Cit/Nfac Delhi ..... Respondent

For Appellant: NoneFor Respondent: Shri P. D. Chougule, Ld. DR
Section 10Section 115BSection 115JSection 139(1)Section 143(1)Section 154Section 250

assessment year beginning on the 1st day of April, 2020. (4) In case of a person, having a Unit in the International Financial Services Centre, as referred to in sub-section (1A) of section 80LA, which has exercised option under sub-section (5), the conditions contained in sub-section

BIGFLEX ENTERPRISES PVT. LTD.,MUMBAI vs. ITO, WARD-8(2)(1), MUMBAI

In the result, the tax appeal is dismissed

ITA 3237/MUM/2024[2020-21]Status: DisposedITAT Mumbai19 Aug 2024AY 2020-21

Bench: Shri Anikesh Banerjee & Shri Gagan Goyalbigflex Enterprises Pvt. Ltd., 2Nd Floor, Parijat House, 1076 Dr. E Moses Road, Worli, Maharashtra 400 018 Pan: Aaccs2112A ..... Appellant Vs. Ito Ward-8(2) (1) Aayakar Bhavan, M. K. Road, Mumbai- 400 020 ..... Respondent

For Appellant: Ms. Mitali Parekh, Ld. ARFor Respondent: Shri Anoop Hiwase, Ld. DR
Section 10Section 10(34)Section 115Section 115BSection 115JSection 143(1)Section 154Section 250

section, no tax on distributed profits shall be chargeable in respect of the total income of a company, being a unit of an International Financial Services Centre, deriving income solely in convertible foreign exchange, for any assessment year on any amount declared, distributed or paid by such company ... interim or otherwise) on or after the 1st day of April, 2017, out of its current incomeor income accumulated as a unit of International Financial Services Centre after the 1st day of April, 2017], either in the hands of the company or the person receiving such dividend. Explanation

DCIT -23(1), MUMBAI, MUMBAI vs. BUSINESS EXCELLANCE TRUST, IL AND FS TRUST COMPANY

In the result, the appeal filed by the Revenue is partly allowed and the cross objection of the assessee is dismissed

ITA 2879/MUM/2023[2018-19]Status: DisposedITAT Mumbai26 Jul 2024AY 2018-19

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaran

For Appellant: Shri Vijay MehtaFor Respondent: Shri S. Srinivasu, CIT-DR
Section 10Section 10(35)Section 10(38)Section 115U

Provided also that nothing contained in sub-clause (b) shall apply to a transaction undertaken on a recognised stock exchange located in any International Financial Services Centre and where the consideration for such transaction is paid or payable in foreign currency: Provided also that nothing contained in this clause shall ... fund shall be computed with reference to the annual average of the monthly averages of the opening and closing figures; (b)"International Financial Services Centre" shall have the same meaning as assigned to it in clause (q) of section 2 of the Special Economic Zones

AILA INFRASTRUCTURE PRIVATE LIMITED,MAHARASHTRA vs. INCOME TAX OFFICER, MUMBAI

In the result, the appeal of the assessee is allowed

ITA 371/MUM/2024[2013-2014]Status: DisposedITAT Mumbai16 May 2024AY 2013-2014

Bench: Shri Anikesh Banerjee & Shri Gagan Goyalm/S. Aila Infrastructure Pvt. Ltd., 8F/95, Sonawala Building, Sleater Road, Tardeo, Mumbai - 400 007. Pan: Aakca 5414B ...... Appellant Vs. Ito Ward 12(1)-1, Room No. 226/262, 2Nd Floor, Aayakar Bhawan, M.K. Road, Mumbai – 400 020. ..... Respondent

For Appellant: Shri M.M. Golwala & Ms. Aruna Aiyar, Ld. ARFor Respondent: Shri Manoj Kumar Sinha, Ld.DR
Section 14Section 143(3)Section 234ASection 234BSection 250Section 69Section 69B

India Act, 1992 (15 of 1992) or regulated under the[Inter-national Financial Services Centre Authority (Fund Management) Regulations, 2022 made under the] International Financial Services Centres Authority Act, 2019 (50 of 2019)]; (ab) "trust" means a trust established under the Indian Trusts Act, 1882 (2 of 1882) or under

DY. COMMISSIONER OF INCOME TAX , CC 5(2) CENTRAL RANGE-5, MUMBAI vs. M/S. WELLKNOWN BUSINESS VENTURES LLP, MUMBAI

In the result, both the appeals of the Revenue are dismissed

ITA 1949/MUM/2022[2019-20]Status: DisposedITAT Mumbai27 Jul 2023AY 2019-20
For Appellant: Shri Mahesh Agrawal/HiteshFor Respondent: Dr. Shyam Prasad (CIT-DR) (on 12.04.2023)/ Shri Manoj Kumar
Section 10(38)Section 133A

Provided also that nothing contained in sub-clause (b) shall apply to a transaction undertaken on a recognised stock exchange located in any International Financial Services Centre and where the consideration for such transaction is paid or payable in foreign currency: Provided also that nothing contained in this clause shall

DY. COMMISSIONER OF INCOME TAX , CC 5(2) CENTRAL RANGE-5, MUMBAI vs. M/S. WELLKNOWN BUSINESS VENTURES LLP, MUMBAI

In the result, both the appeals of the Revenue are dismissed

ITA 1948/MUM/2022[2018-19]Status: DisposedITAT Mumbai27 Jul 2023AY 2018-19
For Appellant: Shri Mahesh Agrawal/HiteshFor Respondent: Dr. Shyam Prasad (CIT-DR) (on 12.04.2023)/ Shri Manoj Kumar
Section 10(38)Section 133A

Provided also that nothing contained in sub-clause (b) shall apply to a transaction undertaken on a recognised stock exchange located in any International Financial Services Centre and where the consideration for such transaction is paid or payable in foreign currency: Provided also that nothing contained in this clause shall

SHIV KUMAR JATIA,NEW DELHI vs. ITO, WARD- 10(2), NEW DELHI

The appeals of the assessee are allowed

ITA 7256/DEL/2019[2011-12]Status: DisposedITAT Delhi26 Apr 2021AY 2011-12

Bench: Sh. Bhavnesh Sainidr. B. R. R. Kumar(Through Video Conferencing) Ita No. 7256/Del/2019 : Asstt. Year : 2011-12 Ita No. 241/Del/2019 : Asstt. Year : 2013-14 Sh. Shiv Kumar Jatia, Vs Income Tax Officer, B-50, Gulmohar Park, Ward-10(2), New Delhi-110049 New Delhi-110002 (Appellant) (Respondent) Pan No. Aabpj7582K Assessee By : Sh. C. S. Aggarwal, Sr. Adv. Revenue By : Sh. Prakash Dubey, Sr. Dr Date Of Hearing: 10.03.2021 Date Of Pronouncement: 26.04.2021

For Appellant: Sh. C. S. Aggarwal, Sr. AdvFor Respondent: Sh. Prakash Dubey, Sr. DR
Section 10Section 10(38)Section 2(24)Section 71Section 74

Provided also that nothing contained in sub-clause (b) shall apply to a transaction undertaken on a recognised stock exchange located in any International Financial Services Centre and where the consideration for such transaction is paid or payable in foreign currency: Provided also that nothing contained in this clause shall ... fund shall be computed with reference to the annual average of the monthly averages of the opening and closing figures; (b) “International Financial Services Centre” shall have the same meaning as assigned to it in clause (q) of section 2 of the Special Economic Zones

SHIV KUMAR JATIA,NEW DELHI vs. ITO, WARD- 10(2), NEW DELHI

The appeals of the assessee are allowed

ITA 241/DEL/2019[2013-14]Status: DisposedITAT Delhi26 Apr 2021AY 2013-14

Bench: Sh. Bhavnesh Sainidr. B. R. R. Kumar(Through Video Conferencing) Ita No. 7256/Del/2019 : Asstt. Year : 2011-12 Ita No. 241/Del/2019 : Asstt. Year : 2013-14 Sh. Shiv Kumar Jatia, Vs Income Tax Officer, B-50, Gulmohar Park, Ward-10(2), New Delhi-110049 New Delhi-110002 (Appellant) (Respondent) Pan No. Aabpj7582K Assessee By : Sh. C. S. Aggarwal, Sr. Adv. Revenue By : Sh. Prakash Dubey, Sr. Dr Date Of Hearing: 10.03.2021 Date Of Pronouncement: 26.04.2021

For Appellant: Sh. C. S. Aggarwal, Sr. AdvFor Respondent: Sh. Prakash Dubey, Sr. DR
Section 10Section 10(38)Section 2(24)Section 71Section 74

Provided also that nothing contained in sub-clause (b) shall apply to a transaction undertaken on a recognised stock exchange located in any International Financial Services Centre and where the consideration for such transaction is paid or payable in foreign currency: Provided also that nothing contained in this clause shall ... fund shall be computed with reference to the annual average of the monthly averages of the opening and closing figures; (b) “International Financial Services Centre” shall have the same meaning as assigned to it in clause (q) of section 2 of the Special Economic Zones