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

50,838, claimed as not chargeable to tax under Article 13 of the India Mauritius (IM Treaty). 3. erred in holding that long term capital gains not chargeable to tax under the IM Treaty form part of the 'total income' of the Appellant as per section

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

50 and the capital gains tax will be charged as if such capital gain is arising out of short-term capital asset. In that case, the capital gains was invested in the manner prescribed in 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.

50 and the capital gains tax will be charged as if such capital gain has arisen out of a short term capital asset but if such capital gain is invested in the manner prescribed in Section

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

50 and the capital\ngains tax will be charged as if such capital gain has arisen out of a short term\ncapital asset but if such capital gain is invested in the manner prescribed in\nSection 54E, then the capital gain shall not be charged under Section

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

50 and the capital gains tax will be charged as if such capital gain has arisen out of a short term capital asset but if such capital gain is invested in the manner prescribed in Section

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

50 ETF – A.Y. 2022-23\n59. In this appeal, the assessee has raised the following grounds: -\n“On the facts and circumstances of the case, the Appellant craves leave to\nprefer an appeal against the order under section 143(3) read with section\n144C(13) of the Act dated 15 January 2025, issued by the Deputy\nCommissioner of Income

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

50 ETF – A.Y. 2022-23\n\n59. In this appeal, the assessee has raised the following grounds: -\n\n“On the facts and circumstances of the case, the Appellant craves leave to\nprefer an appeal against the order under section 143(3) read with section\n144C(13) of the Act dated 15 January 2025, issued by the Deputy\nCommissioner

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

50 ETF – A.Y. 2022-23\n59. In this appeal, the assessee has raised the following grounds: -\n\n“On the facts and circumstances of the case, the Appellant craves leave to\nprefer an appeal against the order under section 143(3) read with section\n144C(13) of the Act dated 15 January 2025, issued by the Deputy\nCommissioner of Income

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

50 ETF – A.Y. 2022-23\n59.\nIn this appeal, the assessee has raised the following grounds:\n“On the facts and circumstances of the case, the Appellant craves leave to\nprefer an appeal against the order under section 143(3) read with section\n144C(13) of the Act dated 15 January 2025, issued by the Deputy\nCommissioner of Income

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

50 ETF – A.Y. 2022-23\n59. In this appeal, the assessee has raised the following grounds: -\n“On the facts and circumstances of the case, the Appellant craves leave to\nprefer an appeal against the order under section 143(3) read with section\n144C(13) of the Act dated 15 January 2025, issued by the Deputy\nCommissioner of Income

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

50 ETF – A.Y. 2022-23\n59. In this appeal, the assessee has raised the following grounds:\n“On the facts and circumstances of the case, the Appellant craves leave to\nprefer an appeal against the order under section 143(3) read with section\n144C(13) of the Act dated 15 January 2025, issued by the Deputy\nCommissioner of Income

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

50 ETF – A.Y. 2022-23\n59. In this appeal, the assessee has raised the following grounds: -\n“On the facts and circumstances of the case, the Appellant craves leave to\nprefer an appeal against the order under section 143(3) read with section\n144C(13) of the Act dated 15 January 2025, issued by the Deputy\nCommissioner of Income

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

50 ETF – A.Y. 2022-23\n59. In this appeal, the assessee has raised the following grounds:\n“On the facts and circumstances of the case, the Appellant craves leave to\nprefer an appeal against the order under section 143(3) read with section\n144C(13) of the Act dated 15 January 2025, issued by the Deputy\nCommissioner of Income

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

50 ETF – A.Y. 2022-23\n59. In this appeal, the assessee has raised the following grounds: -\n“On the facts and circumstances of the case, the Appellant craves leave to\nprefer an appeal against the order under section 143(3) read with section\n144C(13) of the Act dated 15 January 2025, issued by the Deputy\nCommissioner of Income

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

50 ETF – A.Y. 2022-23\n59. In this appeal, the assessee has raised the following grounds: -\n“On the facts and circumstances of the case, the Appellant craves leave to\nprefer an appeal against the order under section 143(3) read with section\n144C(13) of the Act dated 15 January 2025, issued by the Deputy\nCommissioner of Income

FRANK S INTERNATIONAL ITL LIMITED,MUMBAI vs. ACIT(IT), CIRCLE (2)(3)(1), MUMBAI, MUMBAI

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

capital gains in the case of depreciable assets is not only restricted for\nthe purposes of Section 48 or Section 49 of the Act as specifically stated therein and the said fiction\ncreated in sub-section (1) & (2) of Section 50

MORGAN STANLEY MAURITIUS COMPANY LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-CIRCLE 3(2)(2), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Assessment Year: 2020-21 Morgan Stanley Mauritius Company Dy. Cit (International Taxation) – Ltd., Circle 3(2)(2), Vs. C/O S R B C & Associates Llp, 14Th 16Th Floor, Room No. 1615, Air India Floor, The Ruby, 29, Senapati Bapat Building Nariman Point, Marg, Dadar (West), Mumbai-400021. Mumbai-400028. Pan No. Aadcm 5927 G Appellant Respondent

section 270A of the Act for under- reporting of income. reporting of income. The Appellant craves leave to add, alter, vary, omit, substitute, amend The Appellant craves leave to add, alter, vary, omit, substitute, amend The Appellant craves leave to add, alter, vary, omit, substitute, amend or withdraw any or all of the above grounds of appeal and to submit

ACIT CIRCLE-2(1)(1), MUMBAI vs. M/S BOMBAY DYEING & MANUFACTURING CO. LTD. , MUMBAI

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () - A.Y 2014-15 - A.Y 2015-16 Asst. Commissioner Of M/S Bombay Dyeing & Income-Tax 2(1)(1), Mumbai, Manufacturing Co. Ltd Room No.561, 5Th Floor, Vs. Neville House, Jn Herdia Aayakar Bhavan, M.K. Road, Marg, Ballard Estate, Mumbai-400 020 Mumbai-400 001 Pan No. Aaact 2328 K Appellant Respondent - A.Y 2014-15 - A.Y 2015-16 M/S Bombay Dyeing & Dy. Commissioner Of Income- Manufacturing Co. Ltd Tax 2(1), Mumbai, Room Neville House, Jn Herdia No.561, 5Th Floor, Aayakar Vs Marg, Ballard Estate, Bhavan, M.K. Road, Mumbai- Mumbai-400 001 400 020 Pan No. Aaact 2328 K Appellant Respondent

section 45(2) of the Act. The second issue is regarding issue is regarding computation of quantum of long computation of quantum of long-term capital gain, which has been term capital gain, which has been agitated by the assessee in ground no. 1 of its appeal. ated by the assessee in ground no. 1 of its appeal. While ated