RAHUL SAUNIK,MUMBAI vs. ITO WARD 24(3)(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Pawan Singh & Shri Makarand Vasant Mahadeokarrahul Saunik Ito Ward - 24(3)(1), 81 Santosh Tower, Mumbai Lokhandwala, 3Rd Cross Vs. Piramal Chamber, Lane, Andheri (W), Mumbai-400 012. Mumbai – 400 053 Pan/Gir No. Aslps2176G (Applicant) (Respondent) Assessee By Shri Jatin Shah, Ld. Ar Revenue By Shri Annavaram Kosuri, Ld. Dr Date Of Hearing 13.04.2026 Date Of Pronouncement 17.04.2026

section 270A(2) and was liable for penalty. 5. Before the Learned CIT(A), the assessee submitted that he is a salaried individual and income was already subjected to TDS

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 to the extent of Rs.\n1,60,433.\n14. Without prejudice to the above, erred in levying interest under section\n234B amounting to Rs.7,94,29,712 in the computation sheet, annexed with\nthe impugned order;\nInitiation of penal proceedings under section 270A

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 to the extent of Rs.\n1,60,433.\n14. Without prejudice to the above, erred in levying interest under section\n234B amounting to Rs.7,94,29,712 in the computation sheet, annexed with\nthe impugned order;\nInitiation of penal proceedings under section 270A

CONNERSTONE ONDEMAND LIMITED,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

270A of the Act for AY 2017-18 to 2019-20. 2. The assessee is a company incorporated and registered in United Kingdom (UK) and is a cloud-based learning and talent management solutions provider. Cornerstone Ondemand Services India Pvt. Ltd. (CSOD India) is company incorporated in India and is the Authorized Distributor of the assessee's Cloud- based Software

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ACIT(IT)-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

270A of the Act for AY 2017-18 to 2019-20. 2. The assessee is a company incorporated and registered in United Kingdom (UK) and is a cloud-based learning and talent management solutions provider. Cornerstone Ondemand Services India Pvt. Ltd. (CSOD India) is company incorporated in India and is the Authorized Distributor of the assessee's Cloud- based Software

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

270A of the Act for AY 2017-18 to 2019-20. 2. The assessee is a company incorporated and registered in United Kingdom (UK) and is a cloud-based learning and talent management solutions provider. Cornerstone Ondemand Services India Pvt. Ltd. (CSOD India) is company incorporated in India and is the Authorized Distributor of the assessee's Cloud- based Software

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-291)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

270A of the Act for AY 2017-18 to 2019-20. 2. The assessee is a company incorporated and registered in United Kingdom (UK) and is a cloud-based learning and talent management solutions provider. Cornerstone Ondemand Services India Pvt. Ltd. (CSOD India) is company incorporated in India and is the Authorized Distributor of the assessee's Cloud- based Software

CORNERSTONE ONDEMAND LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(1)(1), MUMBAI

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

270A of the Act for AY 2017-18 to 2019-20. 2. The assessee is a company incorporated and registered in United Kingdom (UK) and is a cloud-based learning and talent management solutions provider. Cornerstone Ondemand Services India Pvt. Ltd. (CSOD India) is company incorporated in India and is the Authorized Distributor of the assessee's Cloud- based Software

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 to the extent of Rs.\n1,60,433.\n14. Without prejudice to the above, erred in levying interest under section\n234B amounting to Rs.7,94,29,712 in the computation sheet, annexed with\nthe impugned order;\nInitiation of penal proceedings under section 270A

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 to the extent of Rs.\n1,60,433.\n14. Without prejudice to the above, erred in levying interest under section\n234B amounting to Rs.7,94,29,712 in the computation sheet, annexed with\nthe impugned order;\nInitiation of penal proceedings under section 270A

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 to the extent of Rs.\n1,60,433.\n14. Without prejudice to the above, erred in levying interest under section\n234B amounting to Rs.7,94,29,712 in the computation sheet, annexed with\nthe impugned order;\nInitiation of penal proceedings under section 270A

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 to the extent of Rs.\n1,60,433.\n14. Without prejudice to the above, erred in levying interest under section\n234B amounting to Rs.7,94,29,712 in the computation sheet, annexed with\nthe impugned order;\nInitiation of penal proceedings under section 270A

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 by Rs. 41,16,003. Ground of Appeal No. 7: Initiation of penal proceedings under section 270A of the Act 7. erred

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 by Rs. 41,16,003. Ground of Appeal No. 7: Initiation of penal proceedings under section 270A of the Act 7. erred

BHAVESH GHANSHYAM ADVANI,MUMBAI vs. CIT(INTL TAX)-1,, MUMBAI

In the result, appeals filed by the assessee are dismissed

Bench: Shri Aby T Varkey & Shri Gagan Goyal

TDS Certificate, but obtaining of such certificates and possession of the same by the applicant was neither required as per procedure nor as per law to file the return of income within time. It is further seen from the facts of the case that a letter bearing No. NMS2/ASHPA4344A/6311816 dated 18.12.2014 was issued to the applicant by the Compliance Management

PRANJALI ENTERPRISES P. LTD.,MUMBAI vs. THE ITO-5(2)(4), MUMBAI

In the result, appeal by assessee is dismissed being not maintainable

Bench: Shri Vikas Awasthy & Shri Om Prakash Kantआअसं. 1523/मुं/2020 ("न. व. 2017-18) Pranjali Enterprises Pvt. Ltd., 53, Anand Bhuvan, Banganga Road, Walkeshwar, Mumbai 400 006. Pan: Aaecp-7957-Q ...... अपीलाथ" /Appellant बनाम Vs. The Income Tax Officer-5(2)(4), Room No.566, 5Th Floor, Aaykar Bhavan, M.K.Road, ..... ""तवाद"/Respondent Mumbai- 400 020. अपीलाथ" "वारा/ Appellant By : Shri Vimal Punmiya ""तवाद" "वारा/Respondent By : Shri B.K.Bagchi सुनवाई क" "त"थ/ Date Of Hearing : 06/05/2022 घोषणा क" "त"थ/ Date Of Pronouncement : 09/06/2022 आदेश/ Order

TDS) in ITA No.130 to 135/Del/2015 for assessment year 2010-11 to 2015-16 decided on 19/06/2015 and in the case of Daulat Luthria Nanubhai Mension vs. ACIT in ITA No.4074/Mum/2015 for assessment year 2012-13 to contend that a direction can be given to CIT(A) to decide the stay application. 6. Per contra, Shri B.K.Bagchi representing the Department

BAJAJ AUTO LIMITED,MUMBAI vs. THE PRINCIPAL COMMISSIONER OF INCOME-TAX - 3, MUMBAI, MUMBAI

Bench: Shri Om Prakash Kant () & Shri Narender Kumar Choudhry ()

270A." 7.2 Pursuant to the amendment made in section 155(18), the Central Board of Direct Taxes, vide Notification No. 111 of 2022 dated 28.09.2022, inserted Rule 132 in the Income-tax Rules, 1962, prescribing Form No. 69 for withdrawal of the claim of deduction in respect of surcharge or cess. The said Rule came into effect from

ADDL CIT R G 7(1), MUMBAI vs. NOVARTIS INDIA LTD ( FORMERLY KNOWN AS HINDUSTAN CIBA GIEGY LTD. ), MUMBAI

Bench: Shri Amit Shukla, Hon'Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Novartis India Limited V. Asst. Commissioner Of Income –Tax - 7(2)(2) {Earlier Addl. Commissioner Of Income –Tax – 7(1)} 6Th& 7Th Floor 1St Floor, Aayakar Bhavan Inspire Bkc M.K. Road, Mumbai - 400020 “G” Block, Bkc Main Road Bandra Kurla Complex, Bandra (E) Mumbai – 400051 Pan: Aaach2914F (Appellant) (Respondent) Addl. Commissioner Of Income –Tax – 7(1) V. M/S. Novartis India Limited Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent) Co No.190/Mum/2011 [Arising Out Of Ita No.6772/Mum/2010 (A.Y. 2002-03)] M/S. Novartis India Limited V. Addl. Commissioner Of Income –Tax – 7(1)} Room No. 622, Aayakar Bhavan {Earlier Known As Hindustan Ciba Giegy Ltd.,} Sandoz House, Dr. A.B. Road M.K. Road, Mumbai - 400020 Worli, Mumbai – 400018 Pan: Aaach2914F (Appellant) (Respondent)

TDS, the Dy. CIT had passed an order under section 154 of the Act (see pages 3-5 of Factual paper book-1). 4 25.08.2003 The Dy. CIT issued a notice under section 143(2) of the Act, selecting the Assessee’s ROI for scrutiny (see page 6 of Factual paper book-1). 5 17.10.2003 The Addl. CIT (Transfer Pricing