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

house property,\nprofit and gains from business of profession, capital gains and income from\nother sources. Section 66 to 80 deals with the aggregation of income and set\noff /carry forward of loss.\n7. 1. Hon'ble Bombay High Court in case of CIT vs. M. N. Raigi reported in\n(1949) 17 ITR 180 considered as to whether share

ISHARES CORE MSCI EMERGING MARKETS ETF (AS A SUCCESSOR TO ISHARES CORE EMERGING MARKETS MAURITIUS COMPANY ,MUMBAI vs. DCIT (TP) 2(2)(2), 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

house property, profit and gains from business of profession, capital gains and income from other sources. Section 66 to 80 deals with the aggregation of income and set off /carry forward of loss. 7.1. Hon’ble Bombay High Court in case of CIT vs. M. N. Raigi reported in (1949) 17 ITR 180 considered as to whether share income

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

house property, profit and gains from business of profession, capital gains and income from other sources. Section 66 to 80 deals with the aggregation of income and set off /carry forward of loss. 7.1. Hon’ble Bombay High Court in case of CIT vs. M. N. Raigi reported in (1949) 17 ITR 180 considered as to whether share 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

house property,\nprofit and gains from business of profession, capital gains and income from\nother sources. Section 66 to 80 deals with the aggregation of income and set\noff /carry forward of loss.\n7. 1. Hon'ble Bombay High Court in case of CIT vs. M. N. Raigi reported in\n(1949) 17 ITR 180 considered as to whether share

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

house property,\nprofit and gains from business of profession, capital gains and income from\nother sources. Section 66 to 80 deals with the aggregation of income and set\noff /carry forward of loss.\n7. 1. Hon'ble Bombay High Court in case of CIT vs. M. N. Raigi reported in\n(1949) 17 ITR 180 considered as to whether share

DY CIT CC-1(4), MUMBAI vs. M/S GRASIM INDUSTRIES LTD., MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

house the integral part of the business activity. In such circumstances, the Commissioner relied upon the above judgments and allowed the appeal. He concluded that the loss of Rs. 5.50 crores are a business loss in the hands of the assessee. He set aside the order of the Assessing Officer. 8. The Revenue carried the matter in appeal

GRASIM INDUSTRIES LTD.,MUMBAI vs. DY CIT, CENTRAL CIRCLE-1(4), MUMBAI

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

house the integral part of the business activity. In such circumstances, the Commissioner relied upon the above judgments and allowed the appeal. He concluded that the loss of Rs. 5.50 crores are a business loss in the hands of the assessee. He set aside the order of the Assessing Officer. 8. The Revenue carried the matter in appeal

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

house property,\nprofit and gains from business of profession, capital gains and income from\nother sources. Section 66 to 80 deals with the aggregation of income and set\noff /carry forward of loss.\n7. 1. Hon'ble Bombay High Court in case of CIT vs. M. N. Raigi reported in\n(1949) 17 ITR 180 considered as to whether share

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

house property,\nprofit and gains from business of profession, capital gains and income from\nother sources. Section 66 to 80 deals with the aggregation of income and set\noff /carry forward of loss.\n7. 1. Hon'ble Bombay High Court in case of CIT vs. M. N. Raigi reported in\n(1949) 17 ITR 180 considered as to whether share

TATA MOTORS LTD,MUMBAI vs. ACIT 2(3), MUMBAI

In the result, appeal of the assessee is partly allowed

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.631/मुं/2013 (िन.व. 2008-09) Tata Motors Limited Bombay House, 24,Homi Mody Street, Hutama Chowk, Mumbai – 400001. Pan: Aaact-2727-Q ...... अपीलाथ"/Appellant बनाम Vs. The Addl. Commissioner Of Income Tax Circle -2(3), Mumbai. Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ....."ितवादी/Respondent अपीलाथ" "ारा/ Appellant By : Shri J.D.Mistry, Sr.Advocate With Shri Nikhil Tiwari,Advocate "ितवादी "ारा/Respondent By : Ms. Vatsala Jha, Cit-Dr & Shri Manoj Kumar Singh, Sr.Ar सुनवाई की ितिथ/ Date Of Hearing : 10/11/2023 घोषणा की ितिथ/ Date Of Pronouncement : 05/02/2024 आदेश/Order Per Vikas Awasthy, Jm:

House, 24,Homi Mody Street, Hutama Chowk, Mumbai – 400001. PAN: AAACT-2727-Q ...... अपीलाथ"/Appellant बनाम Vs. The Addl. Commissioner of Income Tax Circle -2(3), Mumbai. Aaykar Bhavan, M.K.Road, Mumbai – 400 020 ....."ितवादी/Respondent अपीलाथ" "ारा/ Appellant by : Shri J.D.Mistry, Sr.Advocate with Shri Nikhil Tiwari,Advocate "ितवादी "ारा/Respondent by : Ms. Vatsala Jha, CIT-DR and Shri Manoj Kumar

EDENRED SA,MUMBAI vs. DCIT (IT) 2(1)(2), MUMBAI

In the result, this appeal by the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

houses. Further, the services offered by Indian group companies need a sophisticated computer program that can monitor, track and maintain such transactions and loyalty/rewards points. The AO further observed that for this purpose the assessee is required to maintain the customer’s individual profile where the personal information, as well as their transaction track, can be kept in the assessee

EDENRED SA,MUMBAI vs. DCIT (IT) 2(1)(2), MUMBAI

In the result, this appeal by the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

houses. Further, the services offered by Indian group companies need a sophisticated computer program that can monitor, track and maintain such transactions and loyalty/rewards points. The AO further observed that for this purpose the assessee is required to maintain the customer’s individual profile where the personal information, as well as their transaction track, can be kept in the assessee

EDENRED SA,MUMBAI vs. ACIT (IT) 2(2)(1), MUMBAI

In the result, this appeal by the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

houses. Further, the services offered by Indian group companies need a sophisticated computer program that can monitor, track and maintain such transactions and loyalty/rewards points. The AO further observed that for this purpose the assessee is required to maintain the customer’s individual profile where the personal information, as well as their transaction track, can be kept in the assessee

EDENRED SA,MUMBAI vs. DCIT (IT) 2(2)(1), MUMBAI

In the result, this appeal by the assessee is allowed

Bench: Shri S. Rifaur Rahman & Shri Sandeep Singh Karhail

houses. Further, the services offered by Indian group companies need a sophisticated computer program that can monitor, track and maintain such transactions and loyalty/rewards points. The AO further observed that for this purpose the assessee is required to maintain the customer’s individual profile where the personal information, as well as their transaction track, can be kept in the assessee

SANJEEV BEHL ,MUMBAI vs. INCOME TAX OFFICER INT TAX WARD, 1(2)(1), MUMBAI

In the result, the appeal by the assessee is allowed

144C(3) of the\nAct, by referring to the provisions of section 10(23AAB) of the Act held that\nthe LIC Market Plus-1 Policy is an annuity/deferred pension plan and proceeds\nfrom the surrender of such annuity/deferred pension plan is taxable as per\nthe provisions of section 80-CCC(2) of the Act. On the basis of the\ncomputation

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

144C(3) 2015-16 Revenue 29. 1890/Mum/2023 ITBA/NFA C/S/250/202 2- 23/1051775 042(1) 31.03.2023 DCIT (TP)- 2(1)(1), Mumbai 23.12.2019 143(3) 2016-17 Assessee 30. 2049/Mum/2023 ITBA/NFA C/S/250/202 2- 23/1051775 042(1) 31.03.2023 DCIT(TP)- 2(1)(1), Mumbai 23.12.2019 143(3) 2016-17 Revenue 31. 1891/Mum/2023 ITBA/NFA C/S/250/202 2- 23/1051775 738(1) 31.03.2023 DCIT-1(1)(2

ILJIN ELECTRIC CO. LTD,MUMBAI vs. DCIT (IT) CIR 2(2)(1), MUMBAI

In the result, appeal for A

Bench: Shri Jason P. Boaz, Accoutant Member & Shri Saktijit Dey

144C(5) of the Income-tax Act, 1961 ('the Act') on the following among other grounds. Ground No. 1: Income in relation to offshore supply is not taxable in India. 1.1 The learned AO / DRP erred in law and in facts in seeking to tax in India, a sum of Rs. 300,65,923 as against the income

CARESTREAM HEALTH INC,MUMBAI vs. DCIT (IT) 2(1)(1), MUMBAI

In the result, the appeal of assessee is allowed

Bench: Shri M.Balaganesh, Am & Shri Amarjit Singh, Jm M/S. Carestream Health Inc Vs. Dy. Commissioner Of C/O. Carestream Health Income Tax, Range-2(1)(1) India Private Limited Scindia House, M.M.Road Sunteck Centre Ballard Pier 1St Floor, Subhash Road Mumbai – 400 028 Vile Parle (E) Mumbai – 400 057 Pan/Gir No. Aaecc6050H (Appellant) .. (Respondent)

House, M.M.Road Sunteck Centre Ballard Pier 1st Floor, Subhash Road Mumbai – 400 028 Vile Parle (E) Mumbai – 400 057 PAN/GIR No. AAECC6050H (Appellant) .. (Respondent) Assessee by Shri Nitesh Joshi Revenue by Shri Padmapani Bora Date of Hearing 29/07/2019 & 08/11/2019 Date of Pronouncement 06/02/2020 आदेश / O R D E R PER M. BALAGANESH (A.M): This appeal in ITA No.826/Mum/2016 for A.Y.2011-12