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

234B of the Act amounting to Rs. 3,31,027/-\nbeing consequential in nature.\nGROUND NO. IV: EXCESS LEVY OF INTEREST U/S 234C OF THE ACT\nAMOUNTING TO RS. 15,763/-\n1. On the facts and circumstances of the case and in law, CIT(A) erred\nin confirming the action of the AO in levying excess interest u/s 234C

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

234B of the Act amounting to Rs. 3,31,027/- being consequential in nature. GROUND NO. IV: EXCESS LEVY OF INTEREST U/S 234C OF THE ACT AMOUNTING TO RS. 15,763/- 1. On the facts and circumstances of the case and in law, CIT(A) erred in confirming the action of the AO in levying excess interest u/s 234C

ANIL MAHAVIR GUPTA,MUMBAI vs. ACIT CEN CIR 45, MUMBAI

In the result, appeal of the assessee allowed

Bench: Shri G.S.Pannu & Shri Sanjay Garg.

3. “On the facts and in the circumstances of the case, and in law, the CIT(A) was not justified in deleting the addition of Rs. 76,50,46,685/ - made u/s 68 of the Act by holding that that the addition made on a/c of the progressive peak balance relating to unexplained sundry creditors was not correct and convincing

ACIT CC-45, MUMBAI vs. ANIL M. GUPTA, MUMBAI

In the result, appeal of the assessee allowed

Bench: Shri G.S.Pannu & Shri Sanjay Garg.

3. “On the facts and in the circumstances of the case, and in law, the CIT(A) was not justified in deleting the addition of Rs. 76,50,46,685/ - made u/s 68 of the Act by holding that that the addition made on a/c of the progressive peak balance relating to unexplained sundry creditors was not correct and convincing

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

234B of the Act amounting to Rs. 3,31,027/-\nbeing consequential in nature.\nGROUND NO. IV: EXCESS LEVY OF INTEREST U/S 234C OF THЕ АСТ\nAMOUNTING TO RS. 15,763/-\n1. On the facts and circumstances of the case and in law, CIT(A) erred\nin confirming the action of the AO in levying excess interest u/s 234C

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

234B of the Act amounting to Rs. 3,31,027/- being consequential in nature.\nGROUND NO. IV: EXCESS LEVY OF INTEREST U/S 234C OF THE ACT AMOUNTING TO RS. 15,763/-\n1. On the facts and circumstances of the case and in law, CIT(A) erred in confirming the action of the AO in levying excess interest u/s 234C

DCIT, CIRCLE-2(1)(1), MUMBAI, MUMBAI vs. M/S KUNDAN JEWELLERS PVT LTD , MUMBAI.

In the result, the appeal filed by the revenue is dismissed

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadaledcit, Circle – 2(1)(1) Vs. M/S. Kundan Jewellers Room No. 561, 5Th Floor Pvt Ltd Aayakar Bhavan, Mk 223, Sm Patil Bldg, Sv Road, Mumbai – 400 020 Road, Andheri (W), Mumbai – 400058. Pan/Gir No. : Aabck5770H Appellant .. Respondent Appellant By : Mr.Nihar Ranjan Samal.Dr Respondent By : Mr.Siddharth Kothari.Ar Date Of Hearing 19.05.2023 Date Of Pronouncement 29 .05.2023 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Revenue Has Filed The Appeal Against The Order Of The National Faceless Appeal Centre (Nfac)/Cit(A), Delhi Passed U/S 143(3) & 250 Of The Act. The Revenue Has Raised The Following Grounds Of Appeal:

234B/ 234C of the Act. This being consequential in nature, Ground no. 4 is worth dismissal, and is dismissed. Ground no.1,2 & 3 are related to one M/s. Kundan Jewellers Pvt Ltd, Mumbai. another andchallenge the one & single addition of Rs. 13,29,50,000on account of unexplained cash credit u/s 68 of the Act. 5.1 Ground

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)

68,115/-. 6.1. xx xx 7. xx xx 8. xx xx 9. We have given a thoughtful consideration to the orders of the authorities below. It is true that different rates of taxes have been provided u/s.115AD and 111A of the Act in respect of gain on non-STT paid shares and STT paid shares but it is also

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)

68,115/-. 6.1. xx xx 7. xx xx 8. xx xx 9. We have given a thoughtful consideration to the orders of the authorities below. It is true that different rates of taxes have been provided u/s.115AD and 111A of the Act in respect of gain on non-STT paid shares and STT paid shares but it is also

KAMLA LANDMARC ENTERPRISES,,MUMBAI vs. DCIT-(3)(4),, MUMBAI

The appeal stands dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Amarjit Singh, Hon'Ble

68 OF THE ACT 1. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in confirming the Order of the AO making addition of unsecured loan, treating the same as bogus in nature solely on the basis of statements of a Partner of the Firm, recorded during the course of search

KAMLA LANDMARC ENTERPRISES,,MUMBAI vs. DCIT(3)(4),, MUMBAI

The appeal stands dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Amarjit Singh, Hon'Ble

68 OF THE ACT 1. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in confirming the Order of the AO making addition of unsecured loan, treating the same as bogus in nature solely on the basis of statements of a Partner of the Firm, recorded during the course of search

KAMLA LANDMARC ENTERPRISES,,MUMBAI vs. DCIT-(3)(4), MUMBAI

The appeal stands dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Amarjit Singh, Hon'Ble

68 OF THE ACT 1. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in confirming the Order of the AO making addition of unsecured loan, treating the same as bogus in nature solely on the basis of statements of a Partner of the Firm, recorded during the course of search

KAMLA LANDMARC ENTERPRISES, ,MUMBAI vs. DCIT-(3)(4),, MUMBAI

The appeal stands dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Amarjit Singh, Hon'Ble

68 OF THE ACT 1. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in confirming the Order of the AO making addition of unsecured loan, treating the same as bogus in nature solely on the basis of statements of a Partner of the Firm, recorded during the course of search

KAMLA LANDMARC ENTERPRISES,,MUMBAI vs. DCIT(3)(4),, MUMBAI

The appeal stands dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Amarjit Singh, Hon'Ble

68 OF THE ACT 1. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in confirming the Order of the AO making addition of unsecured loan, treating the same as bogus in nature solely on the basis of statements of a Partner of the Firm, recorded during the course of search

KAMLA LANDMARC ENTERPRISES,,MUMBAI vs. DCIT(3)(4), CENTRAL CIRCLE,, MUMBAI

The appeal stands dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Amarjit Singh, Hon'Ble

68 OF THE ACT 1. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in confirming the Order of the AO making addition of unsecured loan, treating the same as bogus in nature solely on the basis of statements of a Partner of the Firm, recorded during the course of search

KAMLA LAMDMARC ENTERPRISES,,MUMBAI vs. DCIT(3)(4),, MUMBAI

The appeal stands dismissed

Bench: Shri S. Rifaur Rahman, Hon'Ble & Shri Amarjit Singh, Hon'Ble

68 OF THE ACT 1. On the facts and in the circumstances of the case and in law, the CIT(A) has erred in confirming the Order of the AO making addition of unsecured loan, treating the same as bogus in nature solely on the basis of statements of a Partner of the Firm, recorded during the course of search

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

section 234B of the Act - Rs. 3,68,24,02,310 11. erred in levying interest under Section

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 234B of the Act - Rs. 3,68,24,02,310 11. erred in levying interest under Section