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

234D of the Act.\nShort grant of TDS credit - Rs.236,926\n8. erred in granting 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

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

234D of the Act.\nShort grant of TDS credit - Rs.236,926\n8. erred in granting 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

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

234D of the Act.\nShort grant of TDS credit - Rs.236,926\n8. erred in granting 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

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

Capital losses adopted\nby the Appellant\n\n2. erred in rejecting the hierarchy of set-off of short-term 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

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

234D of the Act.\nShort grant of TDS credit - Rs.236,926\n8. erred in granting 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

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

234D of the Act.\n\nShort grant of TDS credit - Rs.236,926\n\n8. erred in granting TDS credit to Rs.236,926.\n\nInitiation of penal proceedings under section 270A of the Act\n\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

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

234D of the Act.\nShort grant of TDS credit - Rs.236,926\n8. erred in granting 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

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

234D of the Act.\nShort grant of TDS credit - Rs.236,926\n8. erred in granting 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

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)

capital gains by the Assessing Officer is deleted and the Assessing Officer is directed to re- compute the tax liability (including surcharge) as per law accordingly. Thus, in terms of aforesaid, Ground No.1 to 6 raised by the Assessee are allowed. Ground No.7: 17. Ground No.7 raised by the Assessee is directed against the non-grant of credit

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)

capital gains by the Assessing Officer is deleted and the Assessing Officer is directed to re- compute the tax liability (including surcharge) as per law accordingly. Thus, in terms of aforesaid, Ground No.1 to 6 raised by the Assessee are allowed. Ground No.7: 17. Ground No.7 raised by the Assessee is directed against the non-grant of credit

EMERGING MARKETS INDEX NON-LENDABLE FUND ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(2)(1), MUMBAI

In the result, the appeal by the assessee is partly allowed for\nstatistical purposes

234D of the Act amounting\nto Rs.10,020.\nInitiation of penal proceedings under section 270A of the Act\n17. erred in initiating penalty under section 274 r.w.s.270A of the\nAct alleging underreporting of income by the Appellant.\nThe Appellant craves leave to add, alter, vary, omit, substitute or\namend any or all of the above grounds of appeal

EMERGING MARKETS EQUITY INDEX MASTER FUND ,MUMBAI vs. DEPUTY CIT (INT. TAX)-2(2)(1), MUMBAI

In the result, the appeal by the assessee is partly allowed for\nstatistical purposes

234D of the Act amounting\nto Rs.10,020.\nInitiation of penal proceedings under section 270A of the Act\n17. erred in initiating penalty under section 274 r.w.s.270A of the\nAct alleging underreporting of income by the Appellant.\nThe Appellant craves leave to add, alter, vary, omit, substitute or\namend any or all of the above grounds of appeal

I SHARES ESG AWARE MSCI EM ETF ,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\nstatistical purposes

234D of the Act amounting\nto Rs.10,020.\nInitiation of penal proceedings under section 270A of the Act\n17. erred in initiating penalty under section 274 r.w.s.270A of the\nAct alleging underreporting of income by the Appellant.\nThe Appellant craves leave to add, alter, vary, omit, substitute or\namend any or all of the above grounds of appeal

FIDELITY RUTLAND SQUARE TRUST II STRATEGIC ADVISERS FID EMG MARKETS FUND ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )2(3)(1), MUMBAI

capital gains by the Assessing\nOfficer is deleted and the Assessing Officer is directed to re-\ncompute the tax liability (including surcharge) as per law\naccordingly. Thus, in terms of aforesaid, Ground No.1 to 6 raised\nby the Assessee are allowed.\n\n17.\nGround No.7:\nGround No.7 raised by the Assessee is directed against the\nnon-grant of credit

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

capital gains by the Assessing\nOfficer is deleted and the Assessing Officer is directed to re-\ncompute the tax liability (including surcharge) as per law\naccordingly. Thus, in terms of aforesaid, Ground No.1 to 6 raised\nby the Assessee are allowed.\n17. Ground No.7:\nGround No.7 raised by the Assessee is directed against the\nnon-grant of credit

MATRIX PARTNERS INDIA INVESTMENT HOLDINGS, LLC,MAURITIUS vs. DEPUTY COMMISSIONER OF INCOME TAX, MUMBAI

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

Bench: Smt. Beena Pillai () & Ms. Padmavathy S ()

capital gains of INR 31,59,01,013, being a different source and claimed as exempt under Article 13(4) of the India-Mauritius Double Tax Avoidance Agreement ('DTAA'). 2. Erroneous initiation of penalty under section 270A of the Act - On the facts and circumstances of the case and in law, the learned AO has erred in initiating penalty proceedings

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 6(1)(1), MAHARASHTRA

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. Ita No. 6663/Mum/2025 (Assessment Year: 2017-18) 2. Ita No. 6701/Mum/2025 (Assessment Year: 2018-19) 3. Ita No. 6702/Mum/2025 (Assessment Year: 2022-23) & 4. Ita No. 6703/Mum/2025 (Assessment Year: 2023-24) Aditya Birla Sun Life Dcitcircle-6(1)(1), Amc Limited, Room No. 502, 5Th 17Th Floor, One World Vs. Floor, Aayakar Centre Tower-1, Jupiter Bhavan, M. K. Mill Compount, 841, Road, Churchgate, Senapati Bapat Marg, Mumbai-400 020 Delisle Road, S.O. Mumbai-400 013 Pan/Gir No. Aaacb6134D (Applicant) (Respondent) Assessee By Shri Ronak Doshi, Shri Shrey Agrawal & Shri Aadish Jain, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 27.01.2026 Date Of Pronouncement 06.02.2026

capital gains on equity shares. The CIT(A) upheld the said addition and rejected the contention that the same was assessable under a different head. The CIT(A) directed the Assessing Officer to verify and allow correct credit of tax deducted at source and treated the levy of interest under sections 234B and 234C as consequential

ANAND SWARUP MEHTA ,MUMBAI vs. INCOME TAX OFFICER(INTERNATIONAL TAX)-3(2)(1), MUMBAI

In the result, the appeal is accordingly allowed for statistical purposes\nin the above terms

capital gains under section 45 of the Act.\n5. Interest under section 234B and 234D of the Act\nThat on the facts