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

Block, Bandra Kurla Complex, Bandra (East), Mumbai – 400051 ……………… Respondent Assessee by : Shri Pranav Gandhi Revenue by : Shri Satya Pal Kumar, CIT-DR Shri Krishna Kumar, Sr.DR Date of Hearing – 10/12/2025 Date of Order – 02/01/2026 O R D E R PER BENCH The present appeals have been filed by separate assessees against the separate final assessment orders passed under section

TATA COMMUNICATIONS LIMITED,MUMBAI vs. PRINCIPLE COMMISSIONER OF INCOME TAX, MUMBAI

In the result, the question of law referred to the Special Bench is answered in favour of the assessee

Bench: Shri Saktijit Dey & Shri Arun Khodpiatata Communications Limited Pr. Cit, Videsh Sanchar Bhavan, Mumbai-1 Vs. M. G. Road, Fort, Mumbai-400 001 Pan/Gir No. Aaacv 2808 C (Appellant) : (Respondent) Appellant By : Shri J. D. Mistri Respondent By : Shri Ritesh Misra, Cit Dr Date Of Hearing : 25.09.2025 Date Of Pronouncement : 25.09.2025 O R D E R Per Saktijit Dey: The Present Appeal, At The Instance Of The Assessee, Assails Order Dated 21.03.2025, Passed U/S. 263 Of The Income Tax Act, 1961 (‘The Act’ For Short), By Learned Principal Commissioner Of Income Tax (‘Ld. Pcit’ For Short), Pertaining To The Assessment Year (A.Y.) 2018-19. 2. Though The Assessee Has Raised Multiple Grounds, Both On Jurisdictional Issues As Well As On Merits, However, There Is Consensus Between The Parties That The Appeal Can Be Decided On Merits, In Which Event, There Is No Need To Go Into Various Other Issues Raised In Appeal.

gains arising from the transfer of short-term capital assets:] [Provided that in a case where goodwill of a business or profession forms part of a block of asset for the assessment

SAMIR NARAIN BHOJWANI ,MUMBAI vs. DCIT 4(2)(1), MUMBAI

Appeal of the assessee is allowed for statistical purposes and the appeal of the revenue is dismissed

Bench: Shri Anikesh Banerjee, Jm & Ms Padmavathy S, Am

gains arising from the transfer of short- term capital assets:] [Provided that in a case where goodwill of a business or profession forms part of a block of asset for the assessment

ACIT 421 MUMBAI, MUMBAI CITY vs. SAMIR NARAIN BHOJWANI, MUMBAI

Appeal of the assessee is allowed for statistical purposes and the\nappeal of the revenue is dismissed

gains arising from the transfer of short-\nterm capital assets:)\n[Provided that in a case where goodwill of a business or profession forms part of\na block of asset for the assessment

EMPLOYEES RETIREMENT SYSTEM OF TEXAS ,MUMBAI vs. DY CIT (INT. TAX)-2(2)(1), MUMBAI

The appeals are partly allowed

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Block, Bandra Kurla Complex Mumbai - 400051, Maharashtra …………. Respondent Appearance For the Appellant/Assessee : Shri Anish Thackar For the Respondent/Department : Shri Satya Pal Kumar Shri Krishna Kumar Date Conclusion of hearing : 09.06.2025 Pronouncement of order : 13.06.2025 O R D E R Per Bench: 1. These are four appeals preferred by the different assessees pertaining to Assessment Year 2022-2023 challenging four separate

FIDELITY SALEM STREET TRUST FIDELITY SAI EMERGING MARKETS INDEX FUND ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(3)(1), MUMBAI

The appeals are partly allowed

Bench: SHRI NARENDRA KUMAR BILLAIYA, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Block, Bandra Kurla Complex Mumbai - 400051, Maharashtra …………. Respondent Appearance For the Appellant/Assessee : Shri Anish Thackar For the Respondent/Department : Shri Satya Pal Kumar Shri Krishna Kumar Date Conclusion of hearing : 09.06.2025 Pronouncement of order : 13.06.2025 O R D E R Per Bench: 1. These are four appeals preferred by the different assessees pertaining to Assessment Year 2022-2023 challenging four separate

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

Block,\nBandra Kurla Complex, Bandra (East)\nMumbai - 400051\nRespondent\nAssessee by : Shri Anish Thacker\nShri Pranay Gandhi\nRevenue by : Shri Satya Pal Kumar, CIT-DR\nShri Krishna Kumar, Sr.DR\nDate of Hearing – 05/06/2025\nDate of Order - 11/06/2025\nORDER\nPER BENCH\nThe present appeals have been filed by separate assessees against the\nseparate final assessment orders passed under section

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

Block,\nBandra Kurla Complex, Bandra (East)\nMumbai - 400051\nAssessee by : Shri Anish Thacker\nShri Pranay Gandhi\nRevenue by : Shri Satya Pal Kumar, CIT-DR\nShri Krishna Kumar, Sr.DR\nDate of Hearing – 05/06/2025\nRespondent\nDate of Order - 11/06/2025\nORDER\nPER BENCH\nThe present appeals have been filed by separate assessees against the\nseparate final assessment orders passed under section

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

Block,\nBandra Kurla Complex, Bandra (East)\nMumbai - 400051\nRespondent\n\nAssessee by : Shri Anish Thacker\nShri Pranay Gandhi\nRevenue by : Shri Satya Pal Kumar, CIT-DR\nShri Krishna Kumar, Sr.DR\n\nDate of Hearing – 05/06/2025\nDate of Order - 11/06/2025\n\nORDER\nPER BENCH\n\nThe present appeals have been filed by separate assessees against the\nseparate final assessment orders passed

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

Block,\nBandra Kurla Complex, Bandra (East)\nMumbai - 400051\nRespondent\nAssessee by : Shri Anish Thacker\nShri Pranay Gandhi\nRevenue by : Shri Satya Pal Kumar, CIT-DR\nShri Krishna Kumar, Sr.DR\nDate of Hearing – 05/06/2025\nDate of Order - 11/06/2025\nORDER\nPER BENCH\nThe present appeals have been filed by separate assessees against the\nseparate final assessment orders passed under section

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

Block,\nBandra Kurla Complex, Bandra (East)\nMumbai - 400051\nRespondent\nAssessee by : Shri Anish Thacker\nShri Pranay Gandhi\nRevenue by : Shri Satya Pal Kumar, CIT-DR\nShri Krishna Kumar, Sr.DR\nDate of Hearing – 05/06/2025\nDate of Order - 11/06/2025\nORDER\nPER BENCH\nThe present appeals have been filed by separate assessees against the\nseparate final assessment orders passed under section

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

Block,\nBandra Kurla Complex, Bandra (East)\nMumbai - 400051\nAssessee by : Shri Anish Thacker\nShri Pranay Gandhi\nRevenue by : Shri Satya Pal Kumar, CIT-DR\nShri Krishna Kumar, Sr.DR\nDate of Hearing – 05/06/2025\nRespondent\nDate of Order - 11/06/2025\nORDER\nPER BENCH\nThe present appeals have been filed by separate assessees against the\nseparate final assessment orders passed under section

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

Block,\nBandra Kurla Complex, Bandra (East)\nMumbai - 400051\nAssessee by : Shri Anish Thacker\nShri Pranay Gandhi\nRevenue by : Shri Satya Pal Kumar, CIT-DR\nShri Krishna Kumar, Sr.DR\nDate of Hearing – 05/06/2025\nRespondent\nDate of Order - 11/06/2025\nORDER\nPER BENCH\nThe present appeals have been filed by separate assessees against the\nseparate final assessment orders passed under section

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

Block,\nBandra Kurla Complex, Bandra (East)\nMumbai - 400051\nRespondent\n\nAssessee by : Shri Anish Thacker\nShri Pranay Gandhi\nRevenue by : Shri Satya Pal Kumar, CIT-DR\nShri Krishna Kumar, Sr.DR\n\nDate of Hearing – 05/06/2025\nDate of Order - 11/06/2025\n\nORDER\n\nPER BENCH\n\nThe present appeals have been filed by separate assessees against the\nseparate final assessment orders

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

Block,\nBandra Kurla Complex, Bandra (East)\nMumbai - 400051\nRespondent\nAssessee by : Shri Anish Thacker\nShri Pranay Gandhi\nRevenue by : Shri Satya Pal Kumar, CIT-DR\nShri Krishna Kumar, Sr.DR\nDate of Hearing – 05/06/2025\nDate of Order - 11/06/2025\nORDER\nPER BENCH\nThe present appeals have been filed by separate assessees against the\nseparate final assessment orders passed under section

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

Block,\nBandra Kurla Complex, Bandra (East)\nMumbai - 400051\nAssessee by : Shri Anish Thacker\nShri Pranay Gandhi\nRevenue by : Shri Satya Pal Kumar, CIT-DR\nShri Krishna Kumar, Sr.DR\nDate of Hearing – 05/06/2025\nRespondent\nDate of Order - 11/06/2025\nORDER\nPER BENCH\nThe present appeals have been filed by separate assessees against the\nseparate final assessment orders passed under section

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

Block, Bandra Kurla Complex,\nBandra (East), Mumbai – 400051\nRespondent\nAssessee by : Shri Pranav Gandhi\nRevenue by : Shri Satya Pal Kumar, CIT-DR\nShri Krishna Kumar, Sr.DR\nDate of Hearing – 10/12/2025\nDate of Order – 02/01/2026\nORDER\nPER BENCH\nThe present appeals have been filed by separate assessees against the\nseparate final assessment orders passed under section 143(3) read with\nsection

RELIANCE POWER LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 15(3)(1), MUMBAI

In the result, ground of appeal raised by assessee is allowed

Bench: Shri Pawan Singh& Shri Omkareshwar Chidara(Physical Hearing) Dcit – 15(3)(1), Mumbai Reliance Power Limited Room No. 460, 4Th Floor, H-Block, 1St Floor, Dhirubhai Ambani Vs Aayakar Bhavan, M.K. Road, Knowledge City, Koperkhairane, Mumbai – 400020] Navi Mumbai-400710 [Pan: Aaacr2365L] Appellant / Revenue Respondent / Assessee Reliance Power Limited Dcit – 15(3)(1), Mumbai Room No. 460, 4Th Floor, Aayakar Reliance Centre, Ground Floor, 19 Vs Walchand Hirachand Marg, Bhavan, M.K. Road, Ballard Estate, Mumbai – 400001. Mumbai – 400020] [Pan: Aaacr2365L] Appellant / Assessee Respondent / Revenue

block of asset was of Rs. 25.34 lakhs. The differential value of ITA Nos. 890 1348/Mum/2023 & C.O. 71/Mum/2023 Reliance Power Ltd. Rs. 8.58 (8.84 – 25.34 lakhs) was treated as capital gain. The assessee considered such gain as long term capital gain on the ground that it was sold after holding for more than 36 months. During the assessment

FIDELITY RUTLAND SQUARE TRUST II STRATEGIC ADVISERS EMERGING MARKETS FUND ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION), MUMBAI

The appeals are partly allowed

Block,\nBandra Kurla Complex\nMumbai - 400051, Maharashtra\nRespondent\nAppearance\nFor the Appellant/Assessee\nFor the Respondent/Department :\nShri Anish Thackar\nShri Satya Pal Kumar\nShri Krishna Kumar\nDate\nConclusion of hearing\nPronouncement of order\n09.06.2025\n13.06.2025\nORDER\nPer Bench:\n1. These are four appeals preferred by the different assessees\npertaining to Assessment Year 2022-2023 challenging four\nseparate Final Assessment Orders [dated