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

15% amounting to Rs. 796,57,16,860 and the net short-term capital gains\namounting to Rs. 62,90,458 taxable at 30% under section 115AD of the Act.\nBeing aggrieved, the assessee is in appeal before us.\n12. During the hearing, the learned Authorised Representative (“learned\nAR\") submitted that this issue is covered in favour of the assessee

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

15% amounting to Rs. 796,57,16,860 and the net short-term capital gains amounting to Rs. 62,90,458 taxable at 30% under section 115AD of the Act. ITAs No.6050, 6051 & 6774/Mum/2025 (A.Y. 2022-23 & 2023-24) 8 10

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

15(3)(1), Mumbai Reliance Centre, Ground Floor, 19 Vs Room No. 460, Aayakar Bhavan, Walchand Hirachand Marg, M.K. Road, Ballard Estate, Mumbai – 400001. Mumbai – 400020. [PAN: AAACR2365L] Appellant / Assessee Respondent / Revenue Assessee by Shri Niraj Sheth, Advocate Revenue by Shri Umashankar Prasad, CIT-DR Date of Institution 21.03.2023 Date of hearing 07.08.2025 Date of pronouncement 14.10.2025 Order under section

DCIT CEN 5 3, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

15) of the Income-tax tax tax Act, Act, Act, 1961 1961 1961 (“the (“the (“the Act”); Act”); Act”); dividend dividend dividend income income income of of of ₹21,14,67,970/- under section 10(34); and long under section 10(34); and long-term capital gains

DCIT CEN 5 3, MUMBAI, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

15) of the Income-tax tax tax Act, Act, Act, 1961 1961 1961 (“the (“the (“the Act”); Act”); Act”); dividend dividend dividend income income income of of of ₹21,14,67,970/- under section 10(34); and long under section 10(34); and long-term capital gains

DCIT CEN 5 3, MUMBAI, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

15) of the Income-tax tax tax Act, Act, Act, 1961 1961 1961 (“the (“the (“the Act”); Act”); Act”); dividend dividend dividend income income income of of of ₹21,14,67,970/- under section 10(34); and long under section 10(34); and long-term capital gains

DCIT CEN 5 3, MUMBAI, MUMBAI vs. ICICI LOMBARD GENERAL INSURANCE CO. LIMITED, MUMBAI

In the result, appeals of the Revenue are allowed partly

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan ()

15) of the Income-tax tax tax Act, Act, Act, 1961 1961 1961 (“the (“the (“the Act”); Act”); Act”); dividend dividend dividend income income income of of of ₹21,14,67,970/- under section 10(34); and long under section 10(34); and long-term capital gains

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.

10 Tata Communications Limited vs. Pr. CIT off against long term capital loss. This judgment again clarifies the interpretation of section 50 and concept of a long term capital asset. 29. Again in another judgment Hon’ble Bombay High Court in CIT vs Pursarth Trading Co. Pvt Ltd in Income Tax appeal no. 123 of 2013 judgment an order dated

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

15. The IT Act defines "interest" under section 2(28A) as: ‘2. In this Act, unless the context otherwise requires,- …. (28A) "interest" means interest payable in any manner in respect of any moneys borrowed or debt incurred (including a deposit, claim or other similar right or obligation) and includes any service fee or other charge in respect of the moneys

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

capital in\nnature after completion of project when revenue had already been recognized\nfrom the project?\"\nThe assessee before us also filed additional ground which reads as under:\nAdditional Ground No. III: Allowability of maintenance expenses of Rs.\n92.32.199/-\nOn the facts and in the circumstances of the case and in law, the maintenance\nexpenditure

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)

Section 111A of the Act. While that balance Short-Term Capital Gains (STT paid transactions) of INR.1,03,36,950/- be taxed @15% and the Short Term Capital Gains (non-STT paid transaction) be taxed @30% is INR.2,67,46,584/-. 6. In objections filed by the Assessee against the Draft Assessment Order before the DRP, the Assessee placing reliance

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)

Section 111A of the Act. While that balance Short-Term Capital Gains (STT paid transactions) of INR.1,03,36,950/- be taxed @15% and the Short Term Capital Gains (non-STT paid transaction) be taxed @30% is INR.2,67,46,584/-. 6. In objections filed by the Assessee against the Draft Assessment Order before the DRP, the Assessee placing reliance

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

10\n8. In conformity with the directions issued by the learned DRP, the AO\npassed the impugned final assessment order under section 143(3) read with\nsection 144C(13) of the Act computing the net short-term capital gains\namounting to Rs.2,95,96,810 taxable at 15

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

15% under section 111A of the Act\nand the net short-term capital gains amounting to Rs.4,60,58,240 taxable at\n30% under section 115AD of the Act. Being aggrieved, the assessee is in\nappeal before us.\n9. During the hearing, the learned Authorized Representative (“learned\nAR") submitted that this issue is covered in favour of the assessee

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

15% under section 111A of the Act\nand the net short-term capital gains amounting to Rs.4,60,58,240 taxable at\n30% under section 115AD of the Act. Being aggrieved, the assessee is in\nappeal before us.\n9. During the hearing, the learned Authorized Representative (“learned\nAR") submitted that this issue is covered in favour of the assessee

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

capital losses\nadopted by the Appellant and thereby, taxing the gross short-term capital\ngains in respect of transactions on the sale of shares not chargeable to\nSecurities Transaction Tax ('STT\").\n3. failed to appreciate that income under the head 'Capital Gains' is determined\nas per sections 45 to 55A of the Act whilst sections 111A and 115AD only\nprovide

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

15% under section 111A of the Act\nand the net short-term capital gains amounting to Rs.4,60,58,240 taxable at\n30% under section 115AD of the Act. Being aggrieved, the assessee is in\nappeal before us.\n\n9. During the hearing, the learned Authorized Representative (“learned\nAR") submitted that this issue is covered in favour of the assessee

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

15% under section 111A of the Act\nand the net short-term capital gains amounting to Rs.4,60,58,240 taxable at\n30% under section 115AD of the Act. Being aggrieved, the assessee is in\nappeal before us.\n9. During the hearing, the learned Authorized Representative (“learned\nAR\") submitted that this issue is covered in favour of the assessee

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

15% under section 111A of the Act\nand the net short-term capital gains amounting to Rs.4,60,58,240 taxable at\n30% under section 115AD of the Act. Being aggrieved, the assessee is in\nappeal before us.\n9. During the hearing, the learned Authorized Representative (“learned\nAR\") submitted that this issue is covered in favour of the assessee