TELEPERFORMANCE GLOBAL SERVICES P. LTD.,MUMBAI vs. THE ADDL/JT/DY/CIT/ASSTT/ITO, NATIONAL E-ASSESSMENT DENTRE,, DELHI

In the result, the appeal filed by the assessee stands allowed on the additional grounds

Bench: Us, First We Would Like To Address Ground No.2 Wherein The Assessee Has Submitted That The Order Of The Ld. Tpo U/S.92Ca(3) Of The Act Dated 01/11/2019 Is Barred By Limitation & Hence, Invalid In Law.

section 92CA(3) dated 1 November 2019 is barred by limitation and hence invalid in law.‖ 3.1. The additional grounds raised by the assessee are as under:- 1:0 Re: Eloal Assessment Order barred by limitation: 1:1 The Appellant submits that considering the facts and circumstances of its case and the law prevailing on the subject, the impugned Order

ATOS INDIA P.LTD,MUMBAI vs. DCIT RG 14(1)(1), MUMBAI

In the result, the appeal filed by the assessee stands allowed on the additional grounds

Bench: Shri G. S. Pannu & Shri Amit Shukla, Jm आयकरअपीलसं./ I.T.A. No. 1795/Mum/2017 (ननधधारणवर्ा / Assessment Year: 2012-13) Dcit-14(1)1), Atos India Pvt. Ltd., Aayakar Bhavan Godrej & Boyce Complex, बनाम/ Mumbai Plant 5, Pirojshanagar, Vs. Lbs Marg, Vikhroli (West), Mumbai-400079 स्थधयीलेखधसं./जीआइआरसं./ Pan No. Aaaco2461J (अपीलधथी/Appellant) (प्रत्यथी / Respondent) : अपीलधथीकीओरसे/ Appellant By : Shri Dhanesh Bafna /Chandni Sha /Riddhi Maru /Kinjal Patel, Ld. Ars प्रत्यथीकीओरसे/Respondent By : Dr. Yogesh Kamat, Ld. Dr सुनवधईकीतधरीख/ 01.06.2022 & : 25.01.2023 Date Of Hearing घोर्णधकीतधरीख / : 23.02.2023 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla: 1. The Aforesaid Appeal Has Been Filed By The Assessee Against The Final Assessment Order Passed U/S 143(3) R.W.S. 144C(13) In 2

3. Grant of lesser deduction under section 48,53,467 10AA of the Act in respect of remaining units 4. Denial of claim of depreciation on 2,92,19,122 goodwill 5. Disallowance for provision for project 17,16,22,641 risk 6. Disallowance under section 40(a) on 16,65,932 account of non-deduction of TDS on software

STRIDES ARCOLAB LTD,NAVI MUMBAI vs. DCIT CIR 10(3),

Bench: Shri Amit Shukla, Jm & Shri S. Rifaur Rahman, Am आयकरअपीलसं./ I.T.A. No.2877/Mum/2014 (निर्धारणवर्ा / Assessment Year: 2009-10) Strides Shasun Limited Dcit Cir. 15(3)(2) (Formerly Known As R. No. 451, 4Th Floor, Strides Arcolab Limited) बिधम/ Aayakar Bhavan, M. K. 201, Devavrata, Sector 17, Road, Mumbai-400 020 Vs. Vashi, Navi Mumbai – 400 703 स्थायीलेखासं./जीआइआरसं./ Pan No. Aadcs8104P (अपीलाथी/Appellant) (प्रत्यथी / Respondent) : अपीलाथीकीओरसे/ Appellant By : Shri Percy Pardiwala/ Shri Ketan Ved /Shri Ninad Patade, Ld. Ars प्रत्यथीकीओरसे/Respondent By : Ms. Vatsalaa Jha, Ld. Dr सुनवाईकीतारीख/ : 18.01.2023 Date Of Hearing घोषणाकीतारीख / : 28.02.2023 Date Of Pronouncement आदेश / O R D E R Per Amit Shukla : The Aforesaid Appeal Has Been Filed By Assessee Against The Order Dated 26.02.2014 Passed U/S 143(3) R.W.S. 144C(13) In 2

TDS considered short by Rs. 45,06,609/- 16. Credit for tax paid on self-assessment not granted. 3. The assessee vide letter dated 9th June 2022 has raised additional grounds that the impugned transfer pricing order dated 30th January 2013 passed u/s 92CA(3) is barred by limitation and hence bad in law. Further in another petition dated 20th

EDENRED SA,MUMBAI vs. DCIT (IT) 2(1)(2), MUMBAI

In the result, this appeal by the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

TDS of INR 30,00,000: 6. Interest under section 234A of the Act erred in levying interest under section 234A of the Act amounting to INR 32,431 which is not as per law. 7. Interest under section 2348 of the Act Edenred SA A.Y. 2012–13, 2013–14, 2014–15 & 2015–16 erred in levying interest under section

EDENRED SA,MUMBAI vs. ACIT (IT) 2(2)(1), MUMBAI

In the result, this appeal by the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

TDS of INR 30,00,000: 6. Interest under section 234A of the Act erred in levying interest under section 234A of the Act amounting to INR 32,431 which is not as per law. 7. Interest under section 2348 of the Act Edenred SA A.Y. 2012–13, 2013–14, 2014–15 & 2015–16 erred in levying interest under section

EDENRED SA,MUMBAI vs. DCIT (IT) 2(2)(1), MUMBAI

In the result, this appeal by the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

TDS of INR 30,00,000: 6. Interest under section 234A of the Act erred in levying interest under section 234A of the Act amounting to INR 32,431 which is not as per law. 7. Interest under section 2348 of the Act Edenred SA A.Y. 2012–13, 2013–14, 2014–15 & 2015–16 erred in levying interest under section

EDENRED SA,MUMBAI vs. DCIT (IT) 2(1)(2), MUMBAI

In the result, this appeal by the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

TDS of INR 30,00,000: 6. Interest under section 234A of the Act erred in levying interest under section 234A of the Act amounting to INR 32,431 which is not as per law. 7. Interest under section 2348 of the Act Edenred SA A.Y. 2012–13, 2013–14, 2014–15 & 2015–16 erred in levying interest under section

ITO (IT) TDS-2, MUMBAI vs. TATA STEEL LTD, MUMBAI

In the result, the appeal by the assessee is allowed, while the appeal by the Revenue is dismissed

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

TDS-2 Room No. 113, Scindia House, 1st Floor, Ballard Estate, ……………. Appellant N.M. Road, Mumbai-400038 v/s M/s. Tata Steel Ltd 24, Bombay House, Homi ……………. Respondent Mody Street, Fort, Mumbai-400001 PAN – AAACT2803M ITA no.8707/Mum./2011 (Assessment Year : 2007-08) M/s. Tata Steel Ltd 24, Bombay House, Homi ……………. Appellant Mody Street, Fort, Mumbai-400001 PAN – AAACT2803M v/s Additional Commissioner

TATA STEEL LTD,MUMBAI vs. ADDL CIT 2(3), MUMBAI

In the result, the appeal by the assessee is allowed, while the appeal by the Revenue is dismissed

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

TDS-2 Room No. 113, Scindia House, 1st Floor, Ballard Estate, ……………. Appellant N.M. Road, Mumbai-400038 v/s M/s. Tata Steel Ltd 24, Bombay House, Homi ……………. Respondent Mody Street, Fort, Mumbai-400001 PAN – AAACT2803M ITA no.8707/Mum./2011 (Assessment Year : 2007-08) M/s. Tata Steel Ltd 24, Bombay House, Homi ……………. Appellant Mody Street, Fort, Mumbai-400001 PAN – AAACT2803M v/s Additional Commissioner

GOLDMAN SACHS & CO. ,MUMBAI vs. DY CIT (INTERNATIONAL TAXATION)-2(3)(2), MUMBAI

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

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

TDS credit, in accordance with the law, after conducting the necessary verification. As a result, ground no.4 raised in assessee‟s appeal is allowed for statistical purposes. 32. Insofar as the levy of interest under section 234A of the Act is concerned, we deem it appropriate to remand this issue to the file of the Assessing Officer for de novo

GOLDMAN SACHS & CO,MUMBAI vs. DCIT (IT)-2(3)(2), MUMBAI

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

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

TDS credit, in accordance with the law, after conducting the necessary verification. As a result, ground no.4 raised in assessee‟s appeal is allowed for statistical purposes. 32. Insofar as the levy of interest under section 234A of the Act is concerned, we deem it appropriate to remand this issue to the file of the Assessing Officer for de novo

GOLDMAN SACHS & CO.,MUMBAI vs. DCIT- 2(3)(2), MUMBAI, MUMBAI

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

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

TDS credit, in accordance with the law, after conducting the necessary verification. As a result, ground no.4 raised in assessee‟s appeal is allowed for statistical purposes. 32. Insofar as the levy of interest under section 234A of the Act is concerned, we deem it appropriate to remand this issue to the file of the Assessing Officer for de novo

GOLDMAN SACHS & COMPANY,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION) 2(3)(2), MUMBAI

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

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

TDS credit, in accordance with the law, after conducting the necessary verification. As a result, ground no.4 raised in assessee‟s appeal is allowed for statistical purposes. 32. Insofar as the levy of interest under section 234A of the Act is concerned, we deem it appropriate to remand this issue to the file of the Assessing Officer for de novo

DCIT IT 3.1.1, MUMBAI, MUMBAI vs. JEFFERIES LLC , MUMBAI

144C(3) of the Act dated 10\nFebruary 2020, was passed without a document identification number and hence,\nthe order shall be regarded as invalid and deemed to never been issued.\nb. in not providing a copy of the remand report submitted by the Learned AO to\nJLLC.\nThe learned CIT(A) erred in concluding that there is no requirement

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

TDS credit claimed in the return of income amounting to Rs. 1,49,05,83,737; Ground of Appeal No. 18: Levy of interest under section 234B of the Act - Rs. 8,315,107,780 18. erred in levying interest under Section 234B of the Act amounting to Rs. 8,31,51,07,780; Ground of Appeal No. 19: Levy

ISHARES CORE MSCI TOTAL INTERNATIONAL STOCK ETF (AS A SUCCESSOR TO ISHARE CORE TAOTAL INTERNATIONAL STOCK MAURITIUS COMPANY ),MUMBAI vs. DY CIT (INT. TAX)-2(2)(1), 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

TDS credit claimed in the return of income amounting to Rs. 1,49,05,83,737; Ground of Appeal No. 18: Levy of interest under section 234B of the Act - Rs. 8,315,107,780 18. erred in levying interest under Section 234B of the Act amounting to Rs. 8,31,51,07,780; Ground of Appeal No. 19: Levy

M/S PIRAMAL ENTERPRISES LIMIITED ,MUMBSI vs. DY CIT(APPEAL)-RANGE-8(2)(1), MUMBAI

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

Bench: Shri Vikas Awasthy () & Shri Om Prakash Kant () Assessment Year: 2017-18 M/S Piramal Enterprises Ltd., Dy. Cit, Mumbai-8(1)(2), Or Piramal Tower, Agastya National Facelss Assessment Vs. Corporate Park, Lbs Marg, Centre, Delhi, Kamani Junction, Kurla Room No. 624, 6Th Floor, (West), Aayakar Bhavan, M.K. Road, Mumbai-400070. Mumbai-400020. Pan No. Aaacn 4538 P Appellant Respondent : Assessee By Mr. Ronak Doshi : Revenue By Mr. Rakesh Ranjan, Cit-Dr & Mr. Samuel Pitta, Dr : Date Of Hearing 17/11/2022 : Date Of Pronouncement 28/12/2022

144C (13) READ WITH SECTION 144B IS TIME BARRED: 144B IS TIME BARRED: 1. On the facts and in circumstances of the case and in law, 1. On the facts and in circumstances of the case and in law, 1. On the facts and in circumstances of the case and in law, the impugned order passed by Ld. the impugned

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

3) read with section\n144C(13) of the Act dated 15 January 2025, issued by the Deputy\nCommissioner of Income Tax (International Taxation) - 2(2)(2), Mumbai ['the\nlearned AO"] in pursuance of the directions under section 144C(5) of the Act\nissued by the Hon'ble DRP - I, Mumbai dated 5 December 2024 on the following\ngrounds, each