ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE 6(1)(1), MAHARASHTRA

3,29,345/-, and disallowed provision for leave encashment amounting to Rs. 57,63,634/-. The CIT(A) upheld all the aforesaid disallowances and granted limited relief only in respect of short grant of TDS credit by directing verification. Interest under sections 234B

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 6(1)(1), MAHARASHTRA

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. Ita No. 6663/Mum/2025 (Assessment Year: 2017-18) 2. Ita No. 6701/Mum/2025 (Assessment Year: 2018-19) 3. Ita No. 6702/Mum/2025 (Assessment Year: 2022-23) & 4. Ita No. 6703/Mum/2025 (Assessment Year: 2023-24) Aditya Birla Sun Life Dcitcircle-6(1)(1), Amc Limited, Room No. 502, 5Th 17Th Floor, One World Vs. Floor, Aayakar Centre Tower-1, Jupiter Bhavan, M. K. Mill Compount, 841, Road, Churchgate, Senapati Bapat Marg, Mumbai-400 020 Delisle Road, S.O. Mumbai-400 013 Pan/Gir No. Aaacb6134D (Applicant) (Respondent) Assessee By Shri Ronak Doshi, Shri Shrey Agrawal & Shri Aadish Jain, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 27.01.2026 Date Of Pronouncement 06.02.2026

3,29,345/-, and disallowed provision for leave encashment amounting to Rs. 57,63,634/-. The CIT(A) upheld all the aforesaid disallowances and granted (5) ITA No. 6663, 6701, 6702 & 6703 /Mum/2025 Aditya Birla Sun Life AMC Limited limited relief only in respect of short grant of TDS credit by directing verification. Interest under sections 234B

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 6(1)(1), MAHARASHTRA

Accordingly, this ground is allowed

3,29,345/-, and disallowed provision for leave encashment amounting to Rs. 57,63,634/-. The CIT(A) upheld all the aforesaid disallowances and granted limited relief only in respect of short grant of TDS credit by directing verification. Interest under sections 234B

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 6 (1)(1), MAHARASHTRA

Accordingly, this ground is allowed

3,29,345/-, and disallowed provision for leave encashment amounting to Rs. 57,63,634/-. The CIT(A) upheld all the aforesaid disallowances and granted limited relief only in respect of short grant of TDS credit by directing verification. Interest under sections 234B

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

TDS credit amounting to Rs.1,87,39,29,727 as against\nTDS credit claimed in the return of income amounting to Rs.1,88,05,34,623;\nLevy of interest under section 234B of the Act - Rs.4,96,38,028\n14. erred in levying interest under Section 234B of the Act amounting to Rs.\n49,638,028;\nLevy of interest under

DCIT CEN CIR 4 ( 1) CR - 4 ,PR. CIT (C)- 2 , MUMBAI vs. SHRI HARSHAD S. MEHTA, MUMBAI

In the result, appeal of the Revenue is dismissed

Bench: Shri Vikas Awasthy & Shri N.K.Pradhandy.Commissioner Of Income Tax, Central Circle-4(1),Cen.Range-4, Room Nom.1916, 19Th Floor, Air India Bldg., Nariman Point, Mumbai 400 021 ...... Appellant Vs. Shri Harsad S. Mehta, 32, Madhuli, Dr.A.B.Road, Worli, Mumbai – 400 018 Pan:Abapm 1848F ..... Respondent Appellant By : Dr. P.Daniel, Spl. Counsel Respondent By : Shri Dharmesh Shah Date Of Hearing : 09/10/2019 Date Of Pronouncement : 1710/2019

3) or 144 of the Act. For the sake of completeness the relevant extract of the finding of the Tribunal on this issue are reproduced herein below:- “30.8. We heard the rival submissions and considered the same carefully. These grounds relate to the levy and computation of interest under section 234A, 234B and 234C of the Act. Levy of interest

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

TDS credit amounting to Rs.1,87,39,29,727 as against\nTDS credit claimed in the return of income amounting to Rs.1,88,05,34,623;\nLevy of interest under section 234B of the Act - Rs.4,96,38,028\n14. erred in levying interest under Section 234B of the Act amounting to Rs.\n49,638,028;\nLevy of interest under

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

TDS credit amounting to Rs.1,87,39,29,727 as against\nTDS credit claimed in the return of income amounting to Rs.1,88,05,34,623;\nLevy of interest under section 234B of the Act - Rs.4,96,38,028\n14. erred in levying interest under Section 234B of the Act amounting to Rs.\n49,638,028;\nLevy of interest under

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 6,12,875; 6. Interest under section 234A of the Act Erred in levying interest under section 234A of the Act amounting to INR 356 which is not as per law; 7. Interest under section 234B of the Act Erred in levying interest under section 234B of the Act amounting to INR 19,580 disregarding the fact

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 6,12,875; 6. Interest under section 234A of the Act Erred in levying interest under section 234A of the Act amounting to INR 356 which is not as per law; 7. Interest under section 234B of the Act Erred in levying interest under section 234B of the Act amounting to INR 19,580 disregarding the fact

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 6,12,875; 6. Interest under section 234A of the Act Erred in levying interest under section 234A of the Act amounting to INR 356 which is not as per law; 7. Interest under section 234B of the Act Erred in levying interest under section 234B of the Act amounting to INR 19,580 disregarding the fact

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 6,12,875; 6. Interest under section 234A of the Act Erred in levying interest under section 234A of the Act amounting to INR 356 which is not as per law; 7. Interest under section 234B of the Act Erred in levying interest under section 234B of the Act amounting to INR 19,580 disregarding the fact

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

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

TDS credit amounting to Rs.1,87,39,29,727 as against\nTDS credit claimed in the return of income amounting to Rs.1,88,05,34,623;\nLevy of interest under section 234B of the Act - Rs.4,96,38,028\n14. erred in levying interest under Section 234B of the Act amounting to Rs.\n49,638,028;\nLevy of interest under

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

TDS credit amounting to Rs.1,87,39,29,727 as against\nTDS credit claimed in the return of income amounting to Rs.1,88,05,34,623;\nLevy of interest under section 234B of the Act - Rs.4,96,38,028\n14. erred in levying interest under Section 234B of the Act amounting to Rs.\n49,638,028;\nLevy of interest 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

TDS credit amounting to Rs.1,87,39,29,727 as against\nTDS credit claimed in the return of income amounting to Rs.1,88,05,34,623;\nLevy of interest under section 234B of the Act - Rs.4,96,38,028\n14. erred in levying interest under Section 234B of the Act amounting to Rs.\n49,638,028;\nLevy of interest under

HEWLETT PACKARD FINANCIAL SERVICES (INDIA) P. LTD,BANGALORE vs. ASST CIT CIR 2(1)(2), BANGALURU

Accordingly, the ground is dismissed as not pressed

Bench: Smt Beena Pillai, Jm &\Nms Padmavathy S, Am\Ni.T.A. No. 915/Mum/2017\N(Assessment Year: 2011-12)\Nhewlett Packard Financial\Nservices (India) Pvt. Ltd.,\N24, Salarpuria Arena, Hosur Main\Nroad, Adugodi, Bangalore-560030.\Npan: Aabcc5967C\Nappellant)\Nassessee By\Nrevenue By\Ndate Of Hearing\Ndate Of Pronouncement\Nacit, Circle-2(1)(2),\Naayakar Bhavan,\Nvs. M.K. Road, Mumbai-400020.\N:\N:\N:\N:\Nrespondent)\Nshri Percy Pardiwala &\Nmr. Ninad Patade, Ar\Nshri Pravin Salunkhe, Sr. Dr\N22.09.2025\N21.10.2025\Norder\Nper Padmavathy S, Am:\Nthis Appeal By The Assessee Is Against The Order Of The Commissioner Of\Nincome Tax (Appeals)-4, Mumbai [In Short 'Cit(A)'] Passed Under Section 250 Of\Nthe Income Tax Act, 1961 (The Act) Dated 25.10.2016 For Assessment Years (Ay)\N2011-12. The Assessee Raised Grounds Pertaining To The Following Issues:\N(I) Disallowance Of Claim Of Depreciation On \"Hp Indigo Digital Press\Nprinter\" @ 60% - Ground No. 1.1 To 1.7\N(Ii) Treatment Of Ceased Liability As Income U/S 41 - Ground No. 2.1 To\N2.9\N(Iii) Disallowance Of Set Off Of Unabsorbed Depreciation - Ground\Nno. 3.1 To 3.9\N(Iv) Disallowance Of Provision For Tds Certificates & Addition To\Nbook Profits U/S.115Jb - Ground No.

3) but does not talk about the\nunabsorbed depreciation under section 32(2). After the combined perusal of the\nvarious provisions under the Act as discussed herein above, we are inclined to\nagree with the contention of the assessee that the requirement to file the return of\nincome within the due date under section 139(1) is not a condition