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

section 90(2) of the Act, each provision of the Act should be considered separately and therefore for determining 'total income', the income under head "Capital gains" has to be first determined considering the provisions of the Act or the treaty. whichever is more beneficial and once it is determined that the grandfathered gains are not chargeable

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

51,55,529\n4,60,58,240\nShort-term capital loss other than\nthose covered under section 111A\nof the Act\nNIL\nShort-term capital loss covered\nunder section 111A of the Act\n(1,55,58,719)\nNet Short-term capital gains

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

section 111A of the Act\nNet Short-term capital gains\nAmount (INR)\n(Taxable @ 15%)\n4,51,55,529\nAmount

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

section 111A of the Act\nNet Short-term capital gains\nAmount (INR)\n(Taxable @ 15%)\n4,51,55,529\nAmount

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

section 111A of the Act\nNet Short-term capital gains\nAmount (INR)\n(Taxable @ 15%)\n4,51,55,529\nAmount

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

51,55,529\n4,60,58,240\nShort-term capital loss other than\nthose covered under section 111A\nof the Act\nNIL\nShort-term capital loss covered\nunder section 111A of the Act\n(1,55,58,719)\nNet Short-term capital gains

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

section 111A of the Act\nNet Short-term capital gains\nAmount (INR)\n(Taxable @ 15%)\n4,51,55,529\nAmount

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

section 111A of the Act\nNet Short-term capital gains\nAmount (INR)\n(Taxable @ 15%)\n4,51,55,529\nAmount

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

51,55,529\n4,60,58,240\nNIL\nShort-term capital loss covered\nunder section 111A of the Act\n(1,55,58,719)\nNet Short-term capital gains

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

51,55,529\n4,60,58,240\nShort-term capital loss other than\nthose covered under section 111A\nof the Act\nNIL\nShort-term capital loss covered\nunder section 111A of the Act\n(1,55,58,719)\nNet Short-term capital gains

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

51,55,529\n4,60,58,240\nShort-term capital loss other than\nthose covered under section 111A\nof the Act\nNIL\nShort-term capital loss covered\nunder section 111A of the Act\n(1,55,58,719)\nNet Short-term capital gains

SUKHPAL SINGH AHLUWALIA,MUMBAI vs. ITO (INTERNATIONAL TAXATION) WARD 1(1)(1), MUMBAI

In the result, appeal of assessee is partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Raj Kumar Chauhan, Jm Income Tax Officer Sukhpal Singh Ahluwalia (International Tax) Ward 6/24, Milan Building, 1(1)(1), 87, Tardeo Road, Room No.1817A, 18 Th Vs. Opp. Tardeo A C Market, Floor, Air India Building, Mumbai-400 034 Nariman Point, Mumbai-400 021 (Appellant) (Respondent) Pan No. Azupa6884D Assessee By : Shri Rashmikant C. Modi & Ms. Ketki Rajeshirke, Ars Revenue By : Shri Soumendu Kumar Sash, Dr Date Of Hearing: 18.04.2024 27.05.2024 Date Of Pronouncement :

51,198/- for A.Y. 2014-15 totaling to ₹2,87,50,358/-. Assessee disclosed this transaction in schedule BFLA as long- term gain chargeable to tax u/s 112 of the Act. Computation of capital gain on sale of shares of st . Patrick’s Reality limited was made as under:- Sukhpal Singh Ahluwalia; A.Y. 2019-20 No of Purchased Cost Sold

THE DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-6(4), MUMBAI vs. SHRI NARENDRA GEHLAUT, MUMBAI

In the result, the appeal filed by the Revenue is partly allowed e appeal filed by the Revenue is partly allowed for statistical purposes

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2017-18 The Dy. Cit, Central Circle-6(4), Shri Narendra Gehlaut, Room No. 1925, 19Th Floor, Air 875, Sector – 17B, Gurgaon, India Building, Nariman Point, Vs. Haryana, 122 001. Mumbai-400021. Pan No. Aazpg 9630 K Appellant Respondent

capital gain (STCG)’ of Rs. 13,99,61,282/-. (b) The Assessing Officer declined claim of interest claim of interest of Rs. 3,19,28,276/- as cost of acquisition as cost of acquisition, which was paid on paid on housing loan borrowed for acquiring right acquiring right in the flat,. © In respect of flat, the , the developer confirmed

JT. CIT(OSD)CENTRAL CIRCLE-5(1), MUMBAI vs. M/S ASPEN INTERNATIONAL PVT. LTD, MUMBAI

In the result, appeals of the Revenue are allowed for statistical purposes and Cross Objections of the assessee are dismissed

51,049 989% Ltd. 4,62,800 17,58,553 12,95,753 280% Total 42,65,212 4,69,58,072 4,26,92,857 1001% 9. The ld. CIT (A) held that, in his order in the case of M/s. Hazel Mercantile Ltd and Shri Nitin Kumar Dindayal Didwania for A.Y.2010-11 to 2015-16, an addition on account

JT. CIT(OSD)CENTRAL CIRCLE-5(1), MUMBAI vs. M/S ASPEN INTERNATIONAL PVT. LTD , MUMBAI

In the result, appeals of the Revenue are allowed for statistical purposes and Cross Objections of the assessee are dismissed

51,049 989% Ltd. 4,62,800 17,58,553 12,95,753 280% Total 42,65,212 4,69,58,072 4,26,92,857 1001% 9. The ld. CIT (A) held that, in his order in the case of M/s. Hazel Mercantile Ltd and Shri Nitin Kumar Dindayal Didwania for A.Y.2010-11 to 2015-16, an addition on account

JT. CIT (OSD) CENTRAL CIRCLE 5(1), MUMBAI vs. M/S ASPEN INTERNATIONAL PVT LTD, MUMBAI

In the result, appeals of the Revenue are allowed for statistical purposes and Cross Objections of the assessee are dismissed

51,049 989% Ltd. 4,62,800 17,58,553 12,95,753 280% Total 42,65,212 4,69,58,072 4,26,92,857 1001% 9. The ld. CIT (A) held that, in his order in the case of M/s. Hazel Mercantile Ltd and Shri Nitin Kumar Dindayal Didwania for A.Y.2010-11 to 2015-16, an addition on account

JT. CIT (OSD) CENTRAL CIRCLE 5(1), MUMBAI vs. M/S ASPEN INTERNATIONAL PVT LTD., MUMBAI

In the result, appeals of the Revenue are allowed for statistical purposes and Cross Objections of the assessee are dismissed

51,049 989% Ltd. 4,62,800 17,58,553 12,95,753 280% Total 42,65,212 4,69,58,072 4,26,92,857 1001% 9. The ld. CIT (A) held that, in his order in the case of M/s. Hazel Mercantile Ltd and Shri Nitin Kumar Dindayal Didwania for A.Y.2010-11 to 2015-16, an addition on account

JT. CIT (OSD) CENTRAL CIRCLE 5(1), MUMBAI vs. M/S ASPEN INTERNATIONAL PVT LTD, MUMBAI

In the result, appeals of the Revenue are allowed for statistical purposes and Cross Objections of the assessee are dismissed

51,049 989% Ltd. 4,62,800 17,58,553 12,95,753 280% Total 42,65,212 4,69,58,072 4,26,92,857 1001% 9. The ld. CIT (A) held that, in his order in the case of M/s. Hazel Mercantile Ltd and Shri Nitin Kumar Dindayal Didwania for A.Y.2010-11 to 2015-16, an addition on account