GROWMORE EXPORTS LTD,MUMBAI vs. DCIT CC 31, MUMBAI

In the result, the assessee ‘s appeal for the assessment year 2008-09

Bench: Shri Jason P. Boaz & Shri Ram Lal Negi

3). In paragraph 14 of the judgment, the Supreme Court observed as follows: "In Solidaire India Ltd. the provisions of Section 13 of the Special Court (Trial of Offences Relating to Transactions in Securities) Act, 1992 and Section 32 of the Sick Industrial Companies (Special Provisions) Act 1985 were examined and it was held that both these Acts are special

FRANKLIN TEMPLETON INTERNATIONAL SERVICES (INDIA) P.LTD,MUMBAI vs. DCIT CIR 6(3)(1), MUMBAI

TDS from payments to Kone, copies of which were\nsubmitted by the Appellant to the DRP and the AO.\n2.2.2. The learned AO erred on facts and in law in disallowing the\npayment made to Kone without giving any opportunity to the Appellant to\nexplain the position.\n2.3. Further, the learned AO erred on facts and in law in disallowing

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

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

3,29,345/-, and disallowed\nprovision for leave encashment amounting to Rs. 57,63,634/-.\nThe CIT(A) upheld all the aforesaid disallowances and granted\nlimited relief only in respect of short grant of TDS credit by\ndirecting 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 EM UCITS ETF USD DIST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

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;\n\nLevy of interest under section 234B of the Act - Rs.4,96,38,028\n\n14. erred in levying interest under Section 234B of the Act amounting to Rs.\n49,638,028;\n\nLevy

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

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;\n\nLevy of interest under section 234B of the Act - Rs.4,96,38,028\n\n14. erred in levying interest under Section 234B of the Act amounting to Rs.\n49,638,028;\n\nLevy

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

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

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 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(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

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

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