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

TDS of Rs.28,19,510/- was deduced from the total salary paid to the tune of Rs.91,13,252/- by the Employer namely WM Global Sourcing India Pvt. Ltd. as a result thereof the Assessee has claimed refund of Rs.21,92,090/-. Therefore the AO by considering the difference between the amounts of salary received and as per the Form

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. 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

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. 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

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

6 Rahul Saunik assessed income is at par with the returned income and therefore the very condition precedent for invoking section 270A fails. Accordingly, the Learned AR prayed that the penalty of Rs. 8,69,241/- levied under section 270A of the Act be deleted. 10. Per contra, the Learned Departmental Representative strongly relied upon the orders of the Assessing

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.1,997,338.\nInitiation of penal proceedings under section 270A of the Act\n10. erred in initiating penalty under section 274 r.w.s.270A of the Act alleging\nunderreporting of income by the Appellant.\"\n29. Ground no.1 is general in nature. Therefore, the same needs no specific\nadjudication.\n30. The issue arising in grounds no.2 to 6

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 to Rs.1,997,338.\nInitiation of penal proceedings under section 270A of the Act\n10. erred in initiating penalty under section 274 r.w.s.270A of the Act alleging\nunderreporting of income by the Appellant.\"\n29. Ground no.1 is general in nature. Therefore, the same needs no specific\nadjudication.\n30. The issue arising in grounds no.2 to 6

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

TDS to the extent of Rs.\n1,60,433.\n\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;\n\nInitiation of penal proceedings under section 270A of the Act\n\n15. erred in initiating penalty under section 270A

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.1,997,338.\nInitiation of penal proceedings under section 270A of the Act\n10. erred in initiating penalty under section 274 r.w.s.270A of the Act alleging\nunderreporting of income by the Appellant.\"\n29. Ground no.1 is general in nature. Therefore, the same needs no specific\nadjudication.\n30. The issue arising in grounds no.2 to 6

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.1,997,338.\nInitiation of penal proceedings under section 270A of the Act\n10. erred in initiating penalty under section 274 r.w.s.270A of the Act alleging\nunderreporting of income by the Appellant.\"\n29.\nGround no.1 is general in nature. Therefore, the same needs no specific\nadjudication.\n30.\nThe issue arising in grounds no.2 to 6

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.1,997,338.\nInitiation of penal proceedings under section 270A of the Act\n10. erred in initiating penalty under section 274 r.w.s.270A of the Act alleging\nunderreporting of income by the Appellant.\"\n29. Ground no.1 is general in nature. Therefore, the same needs no specific\nadjudication.\n30. The issue arising in grounds no.2 to 6

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.1,997,338.\nInitiation of penal proceedings under section 270A of the Act\n10. erred in initiating penalty under section 274 r.w.s.270A of the Act alleging\nunderreporting of income by the Appellant.\"\n29. Ground no.1 is general in nature. Therefore, the same needs no specific\nadjudication.\n30. The issue arising in grounds no.2 to 6

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

TDS to the extent of Rs.\n1,60,433.\n\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;\n\nInitiation of penal proceedings under section 270A of the Act\n\n15. erred in initiating penalty 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 credit to Rs.1,997,338.\nInitiation of penal proceedings under section 270A of the Act\n10. erred in initiating penalty under section 274 r.w.s.270A of the Act alleging\nunderreporting of income by the Appellant.\"\n29. Ground no.1 is general in nature. Therefore, the same needs no specific\nadjudication.\n30. The issue arising in grounds no.2 to 6

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

6. erred in granting short TDS credit by Rs. 41,16,003. Ground of Appeal No. 7: Initiation of penal proceedings under section 270A

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

6. erred in granting short TDS credit by Rs. 41,16,003. Ground of Appeal No. 7: Initiation of penal proceedings under section 270A