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 to Rs.236,926.\nInitiation of penal proceedings under section 270A of the Act\n9. erred in initiating penalty under section 270A of the Act alleging\nmisreporting of income by the Appellant.\"\n2. The issue arising in grounds no.1 to 4, raised in assessee's appeal,\npertains to the manner of set off of short-term capital loss, which

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 of the Act\n15. erred in initiating penalty under section 270A of the Act alleging\nmisreporting

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

section 143(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 1, Mumbai dated 5 December 2024 on the\nfollowing grounds

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

TDS credit to Rs.236,926.\nInitiation of penal proceedings under section 270A of the Act\n9. erred in initiating penalty under section 270A of the Act alleging\nmisreporting of income by the Appellant.\"\n2. The issue arising in grounds no.1 to 4, raised in assessee's appeal,\npertains to the manner of set off of short-term capital loss, which

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 to Rs.236,926.\nInitiation of penal proceedings under section 270A of the Act\n9. erred in initiating penalty under section 270A of the Act alleging\nmisreporting of income by the Appellant.\"\n2. The issue arising in grounds no.1 to 4, raised in assessee's appeal,\npertains to the manner of set off of short-term capital loss, which

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

TDS credit to Rs.236,926.\n\nInitiation of penal proceedings under section 270A of the Act\n9. erred in initiating penalty under section 270A of the Act alleging\nmisreporting of income by the Appellant.\"\n\n2. The issue arising in grounds no.1 to 4, raised in assessee's appeal,\npertains to the manner of set off of short-term capital

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 to Rs.236,926.\nInitiation of penal proceedings under section 270A of the Act\n9. erred in initiating penalty under section 270A of the Act alleging\nmisreporting of income by the Appellant.\"\n2.\nThe issue arising in grounds no.1 to 4, raised in assessee's appeal,\npertains to the manner of set off of short-term capital loss, which

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 to Rs.236,926.\nInitiation of penal proceedings under section 270A of the Act\n9. erred in initiating penalty under section 270A of the Act alleging\nmisreporting of income by the Appellant.\"\n2.\nThe issue arising in grounds no.1 to 4, raised in assessee's appeal,\npertains to the manner of set off of short-term capital loss, which

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

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

SPE INDIA FILMS HOLDING LLC,MUMBAI vs. ACIT (INTL TAX) -4(2) (2) , MUMBAI

In the result ground no-2 raised by the assessee- is fully allowed

Bench: Shri Amit Shukla & Shri Gagan Goyalspe India Films Holding Llc C/O, Deloitte Haskins & Sells Llp One International Centre, Tower No.3, 27Th Floor-32Nd Floor, Senapati Bapat Marg, Elphinstone Road (W), Mumbai-400013. Pan: Aaocs1827L ...... Appellant Vs. Acit (International Taxation)-4(2)(2) 16Th Floor, Air India Building, Narimaon Point, Mumbai-400021. ..... Respondent Appellant By : Sh. P.J. Pardiwala/Paras Savla Respondent By : Sh. A.K. Keshari Date Of Hearing : 27/06/2022 Date Of Pronouncement : 21/09/2022 Order Per Gagan Goyal, A.M: This Appeal By The Assessee Is Directed Against The Order Of Dispute Resolution Panel-2, Mumbai [Hereinafter Referred To As [‘Drp’] Dated 06.01.2022 For The Assessment Year (Ay) 2018-19. The Assessee Has Raised The Following Grounds Of Appeal: “The Appellant, Objects To The Order Dated 19 January 2022 Passed Under Section 143(3) R.W.S 144C(13) Of The Income Tax Act, 1961 (Act) Passed By The Learned Assistant Commissioner Of Income-Tax (International Taxation) - 4(2)(2), Mumbai

TDS is granted and the income on account of distribution of theatrical rights in India is considered as not taxable, the question of levy of additional interest under section 234B and section 234C of the Act would not arise. 4.3 The Appellant prays that the learned ACIT be directed to delete the levy of additional interest under section 234B

MANISH MANOHARDAS ASRANI ,MUMBAI vs. INT TAX WARD 1(1)(1), MUMBAI

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

Bench: Shri Narender Kumar Choudhry & Shri Gagan Goyalassessment Year: 2019-2000

section 143(C)(3) of the Act. 2.1 On perusing the ITR filed by the Assessee, it was seen by the AO that a sum of Rs.27,79,510/- has been offered by the Assessee to tax under the head “salaries” whereas as per ITR schedule TDS-details of the tax deducted at source from salary as per Form

SALTWATER STUDIO LLP,MUM vs. NATIONAL FACELESS ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Aby T. Varkey, Jm & Shri Om Prakash Kant, Am आयकरअपीलसं/ I.T.A. No.13/Mum/2023 (निर्धारणवर्ा / Assessment Year: 2017-18) बिधम / Saltwater Studio Llp Nfac, Delhi 103, Corporate Corner, F Block, Northe Block, Vs. Sunder Nagar, Near Dalmia New Delhi-110001 College, Malad (West) Mumbai-400 064 स्थधयीलेखधसं/.जीआइआरसं/.Pan/Gir No. : Ackfs1653D (अपीलार्थी / Appellant) .. (प्रत्यर्थी / Respondent)

section 270A of the Act. The AO has made the addition on account of addition made on these issues as under: - Particulars Addition amount 1 Interest paid on late payment of service tax 3,27,026 Interest on Income Tax Refund 2 64,581 3 Interest paid on late payment on TDS

SEADRILL INTERNATIONAL LIMITED ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX-INTERNATIONAL TAXATION-4(2)(1), MUMBAI

The appeal of the assessee is allowed

TDS provisions and CBDT has clarified through various\ncirculars that if GST services are indicated separately in the invoice then no\ntax would be deducted at GST components. By way of illustration following\ncirculars have been referred to before us under various Sections:-\nSr.No.\nCircular No.\nRelevant Section\nCircular No. 5 of 2023\nSection 194BA\nCircular

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

TDS credit amounting to Rs. 1,49,02,70,231 as against\nTDS credit claimed in the return of income amounting to Rs. 1,49,05,83,737;\nGround of Appeal No. 18: Levy of interest under section 234B of the\nAct - Rs. 8,315,107,780\n18. erred in levying interest under Section 234B of the Act amounting

GETINGE MEDICAL INDIA PRIVATE LIMITED ,MUMBAI vs. DCIT 2(2)(1), MUMBAI MAHARASHTRA

In the result, appeal filed by the assessee stands partly allowed

Bench: Smt. Beena Pillai () & Shri Girish Agrawal ()

TDS of Rs. 1,24,82,097/- as against Rs. 1,25,90,372/- claimed by the Appellant in its return of income. 6. Ground 6: Interest charged under section 234A, 2348 and 234C of the Act The Id. AO erred in levying interest under section 234A, 234B and 234C of the Act. 7. Ground 7: Initiation of penalty under

GENERAL REINSURANCE AG,COLOGNE, GERMANY vs. ASSISTANT COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION) CIRCLE - 2(3)(2), MUMBAI

TDS credit in certain cases.", "result": "Partly Allowed", "sections": [ "9(1)(i)", "Article 5(5)", "Article 7", "Article 12(2)", "Article 11(2)", "Section 115JB", "Section 244A", "Section 270A