DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Act. Since the present three appeals preferred by the Revenue pertaining to the Assessment Years 2014-2015, 2015-2016, and 2016-2017 involved identical issues arising from common factual matrix the same were heard together and are, therefore, being disposed off by way of the present common order. With the consent of both the sides we would

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Act. Since the present three appeals preferred by the Revenue pertaining to the Assessment Years 2014-2015, 2015-2016, and 2016-2017 involved identical issues arising from common factual matrix the same were heard together and are, therefore, being disposed off by way of the present common order. With the consent of both the sides we would

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Act. Since the present three appeals preferred by the Revenue pertaining to the Assessment Years 2014-2015, 2015-2016, and 2016-2017 involved identical issues arising from common factual matrix the same were heard together and are, therefore, being disposed off by way of the present common order. With the consent of both the sides we would

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Act. Since the present three appeals preferred by the Revenue pertaining to the Assessment Years 2014-2015, 2015-2016, and 2016-2017 involved identical issues arising from common factual matrix the same were heard together and are, therefore, being disposed off by way of the present common order. With the consent of both the sides we would

DCIT-3(1)(1), MUMBAI, MUMBAI vs. RELCON INFRAPROJECTS LTD., MUMBAI

Bench: SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

270A of the Act. Since the present three appeals preferred by the Revenue pertaining to the Assessment Years 2014-2015, 2015-2016, and 2016-2017 involved identical issues arising from common factual matrix the same were heard together and are, therefore, being disposed off by way of the present common order. With the consent of both the sides we would

MKF INTERNATIONAL,MUMBAI vs. DCIT CIRCLE 17(1), MUMBAI

In the result, the appeal of the assessee is allowed

Bench: Shri Saktijit Dey & Shri Makarand Vasant Mahadeokarmkf International Dcit Circle 17(1), 1903/1905, Aarus Wing, Kautilya Bhavan, Wallace Fortuna, Shivdas Vs. Bkc, Mumbai – Chapsi Marg, Opp-Fazlani 400 051 School, Chinchbunder Ho, Mumbai-400 009 Pan/Gir No. Abhfm5244N (Applicant) (Respondent) Assessee By Shri Dharmesh Shah A/W Ms. Mitali Parekh, Ld. Ars Revenue By Shri Umashankar Prasad, Ld. Dr Date Of Hearing 10.02.2026 Date Of Pronouncement 12.02.2026

68 and brought the same to tax at the special rate under section 115BBE. Penalty proceedings under section 270A

COCOCART VENTURES PRIVATE LIMITED ,MUMBAI vs. INCOME TAX OFFICER WARD 14(1)(1), MUMBAI

In the result the appeal filed by the assessee stands allowed

Bench: Smt. Beena Pillai () & Smt. Renu Jauhri ()

68, for the grant of immunity from Imposition of penalty under Section 270A of the Income Tax Act, 1961. 5. The Ld. AO further

BAO VALUE FUND,MUMBAI vs. ACIT, INTERNATIONAL TAX, CIRCLE-1(2)(1), MUMBAI

The appeal of the assessee is allowed

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

68 of the Act were not applicable to the appellant. The appellant prays that such computation of tax liability was without any application of mind and should be deleted. 6. On the facts and circumstances of the case and in law, the AO had erred in levying surcharge 25% on the tax liability computed as per Section 115BBE

SUSHIL RAJENDRA KOTHARI ,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 19(3), , MUMBAI

In the result, the appeals of the assessee is allowed

Bench: Shri Sandeep Gosain, Jm & Ms Padmavathy S, Am

270A of the Act of Rs 1129012 and completely ignored the facts and merits of the case. 2. The learned NFAC CIT (A) erred in Completely ignoring the fact that learning AO has not passed an order for rejection or granting of Immunity as Form 68 was duly submitted before the AO. The AO was duly bond to pass

NATHAN ANIL RAO, MUMBAI vs. THE ITO -CIRCLE 23(1), MUMBAI

In the result, appeal of the assessee is allowed for statistical

Bench: Shri Om Prakash Kant (Account Member) & Ms. Kavitha Rajagopal () Assessment Year: 2017-18

68,972; Erroneous levy of interes Erroneous levy of interest under section 234D of the Act 9. erred in levying interest under section 234D of INR 61,387; 9. erred in levying interest under section 234D of INR 61,387; Initiation of penalty proceedings under Section 27 Initiation of penalty proceedings under Section

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)

270A of the Act alleging under reporting of income by the Appellant.” Assessment Year 2022-2023 Ground No.1 to 6: 3. The relevant facts in brief are that the Assessee, a trust organized in the United States of America, is registered with the Securities and Exchange Board of India (SEBI) as a Foreign Portfolio Investor. The Assessee makes portfolio investments

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)

270A of the Act alleging under reporting of income by the Appellant.” Assessment Year 2022-2023 Ground No.1 to 6: 3. The relevant facts in brief are that the Assessee, a trust organized in the United States of America, is registered with the Securities and Exchange Board of India (SEBI) as a Foreign Portfolio Investor. The Assessee makes portfolio investments

MEHUL PRAVINCHANDRA SHETH ,MUMBAI vs. DCIT, C.C 1(2), MUMBAI

In the result, the appeal of the assessee bearing ITA No

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

68 electronically on 18.06.2023 under section 270AA(2) of the Act, seeking immunity from imposition of penalty under section 270A

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

68,24,02,310 Ground of Appeal No. 12: Initiation of penal proceedings under section 270A of the Act 12. erred

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

68,24,02,310 Ground of Appeal No. 12: Initiation of penal proceedings under section 270A of the Act 12. erred

PRATHAMESH VIVEK KHOT,MUMBAI vs. INCOME TAX OFFICER CIRCLE 41 2 1, MUMBAI

In the result, appeal of the assessee is allowed as indicated above for statistical purposes

Bench: Shri Vikas Awasthy, Jm & Shri Prashant Maharishi, Am Income Tax Officer, Prathamesh Vivek Khot 1502-1503 Dreams 1-A Wing, National E-Assessment Lbs Marg Bhandup (W), Centre, Delhi Vs. Mumbai-400 078 Maharashtra-400 078 (Appellant) (Respondent) Pan No. Bsbpk6695K Assessee By : Shri Mandar Vaidya, Ar Revenue By : Shri H.M. Bhatt, Dr Date Of Hearing: 18.12.2023 Date Of Pronouncement : 31.01.2024

section 270A of the act. 05. The learned AO held that assessee has not filed a formal application for immunity from levy of penalty in the prescribed form number 68

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

270A of the\nAct alleging under reporting of income by the Appellant.”\n4. Ground No.1 to 6:\nThe relevant facts in brief are that the Assessee, a trust\norganized in the United States of America, is registered with the\nSecurities and Exchange Board of India (SEBI) as a Foreign\nPortfolio Investor. The Assessee makes portfolio investments in\nIndian securities

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

270A of the Act\nalleging under reporting of income by the Appellant.”\n4\n\nITA No. 2125, 2126, 2127 & 2155/Mum/2025\n Assessment Year 2022-2023\n\n3.\nGround No.1 to 6:\nThe relevant facts in brief are that the Assessee, a trust\norganized in the United States of America, is registered with the\nSecurities and Exchange Board of India (SEBI