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

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

68 was duly submitted before the AO. The AO was duly bond to pass an order either granting or rejecting the immunity, penalty levied by AO, Confirmed by NFAC CIT (A) in is bad in law. 3. The learned NFAC CIT (A) Without Jurisdiction erred in concluding that Interest paid in excess of Interest received was a shift from sound

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 were also initiated. 6. Aggrieved, the assessee preferred appeal before the CIT(A). Before CIT(A), the assessee reiterated that capital was introduced by partners through banking channels, funds represented income earned outside India, identity of partners stood established

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

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 on 19/04/2024, seeking immunity from imposition of penalty u/s. 270A of the Act. It was submitted that, the assessee made payment of demand raised along with assessment order dated 22/03/2024 and also did not file any appeal before the Ld.CIT(A) simultaneously, it is submitted that, the assessee filed rectification application u/s.154 of the Act seeking rectification of mistake

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

8. erred in levying interest under section 234C of INR 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

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

270A of the Act, which is premature in nature. Therefore, the said ground is dismissed. 38. In the result, the appeal by the assessee is partly allowed for statistical purposes. ITA No.6774/Mum./2025 iShares Core MSCI Total International Stock ETF - A.Y. 2023-24 39. In this appeal, the assessee has raised the following grounds: - ITAs No.6050, 6051 & 6774/Mum/2025

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

270A of the Act, which is premature in nature. Therefore, the said ground is dismissed. 38. In the result, the appeal by the assessee is partly allowed for statistical purposes. ITA No.6774/Mum./2025 iShares Core MSCI Total International Stock ETF - A.Y. 2023-24 39. In this appeal, the assessee has raised the following grounds: - ITAs No.6050, 6051 & 6774/Mum/2025

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

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 before the Ld. AO, seeking grant of immunity from penalty under section 270A of the Act. Bu the Ld. AO proceeds to impose penalty U/s 270A of the Act. Aggrieved by the above, the assessee filed an appeal before the Ld. CIT(A). The Ld. CIT(A) upheld the impugned penalty order. Being aggrieved assessee

KAVITA JASJIT SINGH,MUMBAI vs. CIT (A), CIR-3(1)(1), MUMBAI

In the result, the appeal by the assessee is partly allowed

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

section 270A of the Act. 8. The brief facts of the case pertaining to this issue, as emanating from the record, are: The assessee is an individual and for the year under consideration filed the return of income on 30/10/2017, declaring a total income of Rs.1,88,68

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

68,115/-.\n6.1.\nXX\nXX\n7. XX\nXX\n8. XX\nXX\n9. We have given a thoughtful consideration to the\norders of the authorities below. It is true that\ndifferent rates of taxes have been provided\nu/s.115AD and 111A of the Act in respect of gain on\nnon-STT paid shares and STT paid shares but it is\nalso

M/S CELIO FUTURE FASHION PRIVATE LIMITED,MUMBAI vs. ADDL/JT/CIT/DY/ASSTT/ITO/NFAC, DELHI, DELHI

In the result, the appeal by the assessee is partly allowed for statistical purposes

Bench: Shri Prashant Maharishi & Shri Sandeep Singh Karhail

270A and 271AAC(1) of the Act. M/s. Celio Future Fashion Pvt. Ltd. ITA no.741/Mum./2022 5. The appellant craves leave to add, alter, delete, rectify and modify any of the grounds of appeals before or at the time of hearing the appeal. 3. The issue arising in ground no.1, raised in assessee‟s appeal, is pertaining to transfer pricing