ISHARES CORE MSCI EMERGING MARKETS ETF (AS A SUCCESSOR TO ISHARES CORE EMERGING MARKETS MAURITIUS COMPANY ,MUMBAI vs. DCIT (TP) 2(2)(2), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical purposes

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailishares Core Msci Emerging Markets Etf (As A Successor To Ishares Core Emerging Markets Mauritius Company) C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, ............... Appellant Dadar (West), Mumbai - 400028 Pan : Aafci3337N V/S Deputy Commissioner Of Income Tax (International Tax) - 2(2)(2) Room No.606, 6Th Floor, Kautilya Bhavan, ……………… Respondent C-41 To C-43, G-Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 Ishares Msci All Country Asia Ex Japan Etf C/O Ernst & Young Llp, 17Th Floor, The Ruby, 29, Senapati Bapat Marg, Dadar (West), Mumbai - 400028 Pan : Aabti7439L ............... Appellant

carry forward of the loss as claimed by the assessee.” ITAs No.6050, 6051 & 6774/Mum/2025 (A.Y. 2022-23 & 2023-24) 23 27. Therefore, from a careful perusal of these decisions, it is evident that all the submissions of the Revenue, raised in the instant appeal, have already been considered by the Co-ordinate Benches. Thus, respectfully following the decisions

ISHARES CORE MSCI TOTAL INTERNATIONAL STOCK ETF (AS A SUCCESSOR TO ISHARES CORE TOTAL INTERNATIONAL STOCK MAURITIUS CO ),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

carried\nforward without utilizing such\nbrought forward short-term\ncapital loss was set off\n018. Provisions of section 70 of the income tax act provides for the set off of\nlosses from one source against income from another source under the same\nhead of income. According to section 70 (1) where assessee suffers loss in\nrespect of any source under

ISHARES MSCI EMERGING MARKETS ETF (AS A SUCCESSOR TO ISHARES EMERGING MARKETS INDEX MAURITIUS CO ),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical\npurposes

carried\nforward without utilizing such\nbrought forward short-term\ncapital loss was set off\n018. Provisions of section 70 of the income tax act provides for the set off of\nlosses from one source against income from another source under the same\nhead of income. According to section 70 (1) where assessee suffers loss in\nrespect of any source under

ISHARES MSCI INDIA ETF(AS A SUCESSOR TO ISHARES INDIA INDEX MARUITIUS COMPANY),MUMBAI vs. DCIT (INT)-2(2)(2), MUMBAI

carried\nforward without utilizing such\nbrought forward short-term\ncapital loss was set off\n018. Provisions of section 70 of the income tax act provides for the set off of\nlosses from one source against income from another source under the same\nhead of income. According to section 70 (1) where assessee suffers loss in\nrespect of any source under

SCHWAB EMERGING MARKETS EQUITY ETF ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX INTERNATIONAL TAXATION -4(2)(1), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical\npurposes

carry forward, and therefore, if there is any income\nduring the year, whether exempt or not, and there is a loss and it fulfils the\nconditions laid down in section 70, then there must be set off first then only\nthe remaining loss will be carried forward. The AO held that if the income itself\nis not part of total

ISHARES CORE MSCI EMERGING MARKETS ETF (AS A SUCESSOR TO ISHARES CORE EMERGING MARKETS MAURITIUS COMPANY),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) 2(2)(2), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical\npurposes

carried\nforward without utilizing such\nbrought forward short-term\ncapital loss was set off\n018. Provisions of section 70 of the income tax act provides for the set off of\nlosses from one source against income from another source under the same\nhead of income. According to section 70 (1) where assessee suffers loss in\nrespect of any source under

ISHARES MSCI ALL COUNTRY ASIA EX JAPAN ETF(AS A SUCCESSOR TO ISHARES MSCI ALL COUNTRY ASIA EX JAPAN MAURITIUS CO),MUMBAI vs. DCIT (INT)-2(2)(2), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical\npurposes

carried\nforward without utilizing such\nbrought forward short-term\ncapital loss was set off\n018. Provisions of section 70 of the income tax act provides for the set off of\nlosses from one source against income from another source under the same\nhead of income. According to section 70 (1) where assessee suffers loss in\nrespect of any source under

EDIL COMMODITIES LTD,MUMBAI vs. DCIT CIR 3(1), MUMBAI

In the result, these appeals by the assessee stands partly allowed

Bench: Shri Shamim Yahya, Am & Shri Amarjit Singh, Jm आयकर अपील सं./I.T.A. No.3426/Mum/2016 ("नधा"रण वष" / Assessment Year: 2011-12) M/S. Edel Commodities Limited Dy. Cit, Circle 3(1), बनाम/ Edelweiss House, Off Cst Road, Mumbai Vs. Kalina, Santacruz, Mumbai-400 098 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. Aacce 0323 K (Assessee) (Revenue) : & आयकर अपील सं./I.T.A. No.3576/Mum/2016 ("नधा"रण वष" / Assessment Year: 2011-12) Acit – 3(1)(2), M/S. Edel Commodities Limited बनाम/ Room No. 607, 6Th Floor, Edelweiss House, Off Cst Road, Aayakar Bhavan, Mumbai-400 020 Kalina, Santacruz, Mumbai-400 098 Vs. "थायी लेखा सं./जीआइआर सं./Pan/Gir No. Aacce 0323 K (Revenue) : (Assessee) अपीलाथ" क" ओर से / Appellant By : Shri Vijay Mehta ""यथ" क" ओर से/Respondent By : Shri Ram Tiwari सुनवाई क" तार"ख / : 22.01.2018 Date Of Hearing घोषणा क" तार"ख / : 06.04.2018 Date Of Pronouncement आदेश / O R D E R Per Shamim Yahya, A. M.: These Are Cross Appeals By The Assessee & The Revenue Arising Out Of The Order Of The Ld. Commissioner Of Income Tax (Appeals) Dated 15.2.2016 & Pertain To The Assessment Year 2011-12. M/S. Edel Commodities Limited Assessee’S Appeal

carried forward of speculation losses of the earlier year, before allowing any other losses to be adjusted against those profits. Hence, it is clear that there is no bar in adjustment of unabsorbed business losses from speculation profit of the current year, provided the speculation losses for the year and earlier has been first adjusted from speculation profit

ISHARES MSCI INDIA UCITS ETF ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(2)(2), MUMBAI

carried\nforward without utilizing such\nbrought forward short-term\ncapital loss was set off\n\n018. Provisions of section 70 of the income tax act provides for the set off of\nlosses from one source against income from another source under the same\nhead of income. According to section 70 (1) where assessee suffers loss in\nrespect of any source

ISHARES MSCI EM UCITS ETF USD DIST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

carried\nforward without utilizing such\nbrought forward short-term\ncapital loss was set off\n\n018. Provisions of section 70 of the income tax act provides for the set off of\nlosses from one source against income from another source under the same\nhead of income. According to section 70 (1) where assessee suffers loss in\nrespect of any source

ISHARES INDIA 50 ETF (AS A SUCCESSOR TO ISHARES INDIA MAURITIUS CO ),MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical\npurposes

carried\nforward without utilizing such\nbrought forward short-term\ncapital loss was set off\n018. Provisions of section 70 of the income tax act provides for the set off of\nlosses from one source against income from another source under the same\nhead of income. According to section 70 (1) where assessee suffers loss in\nrespect of any source under

ISHARES CORE MSCI EM IMI UCITS ETF,MUMBAI vs. DCIT (INT)-2(2)(2), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical\npurposes

carried\nforward without utilizing such\nbrought forward short-term\ncapital loss was set off\n3.\n018. Provisions of section 70 of the income tax act provides for the set off of\nlosses from one source against income from another source under the same\nhead of income. According to section 70 (1) where assessee suffers loss in\nrespect of any source

ISHARES MSCI ALL COUNTRY ASIA EX JAPAN ETF,MUMBAI vs. DCIT (INT. TAX)-2(2)(2), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical\npurposes

forward short-term and long-term\ncapital loss amounting to Rs. 3,19,12,67,554 and Rs. 26,50,63,39,311\nrespectively in the computation sheet appended to the impugned order as\nagainst allowing the same in the impugned order;\n14. erred in computing gross total income as Rs. 4,88,17,61,36,880 in the\ncomputation

DAGA GLOBAL CHEMICALS LTD,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX-12(2)(1), MUMBAI

In the result, the appeal filed by the assessee and the Revenue are

Bench: Shri Shamim Yahya & Shri Amarjit Singhm/S. Daga Global Chemicals D C I T - 12(2)(1) P. Ltd. Room No. 223/262 101, Mahek Plaza 2Nd Floor, Aayakar Bhavan Vs. Off L.T. Road, Maharashtra M.K. Road, Mumbai 400020 Nagar Lane, Borivali (W) Mumbai 400092 Pan – Aaacd2233M Appellant Respondent D C I T - 12(2)(1) M/S. Daga Global Chemicals Room No. 223/262 P. Ltd. 2Nd Floor, Aayakar Bhavan 101, Mahek Plaza Vs. M.K. Road, Mumbai 400020 Off L.T. Road, Maharashtra Nagar Lane, Borivali (W) Mumbai 400092 Appellant Respondent

TDS, entire amount of commission paid is disallowed under section 40(a)(i). 3. “Whether on the facts and in the circumstances of the case and in law, the ld. CIT(A) erred in allowing the appeal of the assessee to carry forward of long term capital loss

THERMO FISHER SCIENTIFIC INDIA P. LTD,MUMBAI vs. DCIT 15(3)(1), MUMBAI

In the result, the appeal by the assessee is partly allowed for statistical\npurposes

carried forward and brought forward as per the original\nreturn of income of AY 2009-10 and AY 2010-11 respectively.\n8.2 On the facts and in the circumstances of the case and in law, the learned\nDCIT and Hon'ble DRP erred in not allowing brought forward and consequent\nset off of the unabsorbed depreciation

BANK OF INDIA,MUMBAI vs. DCIT - 2(1)(1), MUMBAI

In the result, the appeal is partly allowed for statistical purposes in the terms indicated above

TDS, on dividend income received from foreign associates of the bank, amounting to Rs 87,54,656 and the Hon’ble CIT(A) erred in confirming the said disallowance. The learned CIT(A) be directed to allow the credit for the aforesaid taxes paid outside India, under section 90 and 91, and enhance the refund due to the appellant bank

HYBRID FINANCIAL SERVICES LTD,MUMBAI vs. DCIT 8(2), MUMBAI

Appeals of the Assessee are hereby Partly Allowed

Bench: Shri G.S.Pannu, Am & Shri Amarjit Singh, Jm आयकरअपीलसं/ I.T.A. No.6303/M/12, I.T.A. No. 326/M/14 & 6571/M/14 (िनधा"रणवष" / Assessment Year: 2009-10,2010-11 & 2011-12) बनाम/ Hybrid Financial Services Asst. Commissioner Of Limited Income Tax 10(3) Vs. 17-A Wing, 2Nd Floor, Room No.473, Raj Industrial Estate Aayakar Bhavan, M.K.Road, Premises Ltd., Mumbai - 400020 Military Road, Marol, Andheri(East), Mumbai - 400059 "थायीलेखासं./जीआइआरसं./Pan/Gir No. : Aaacm2824M (अपीलाथ" /Appellant) (""थ" / Respondent) ..

TDS. 6. CIT(Appeals) erred in not considering the long term capital losses of the current year to be carried forward

HYBRID FINANCIAL SERVICES LTD,MUMBAI vs. DCIT 8(2), MUMBAI

Appeals of the Assessee are hereby Partly Allowed

Bench: Shri G.S.Pannu, Am & Shri Amarjit Singh, Jm आयकरअपीलसं/ I.T.A. No.6303/M/12, I.T.A. No. 326/M/14 & 6571/M/14 (िनधा"रणवष" / Assessment Year: 2009-10,2010-11 & 2011-12) बनाम/ Hybrid Financial Services Asst. Commissioner Of Limited Income Tax 10(3) Vs. 17-A Wing, 2Nd Floor, Room No.473, Raj Industrial Estate Aayakar Bhavan, M.K.Road, Premises Ltd., Mumbai - 400020 Military Road, Marol, Andheri(East), Mumbai - 400059 "थायीलेखासं./जीआइआरसं./Pan/Gir No. : Aaacm2824M (अपीलाथ" /Appellant) (""थ" / Respondent) ..

TDS. 6. CIT(Appeals) erred in not considering the long term capital losses of the current year to be carried forward