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

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

9,40,590 2017 – 18 7,30,88,524 7,76,720 2018 – 19 8,85,94,455 5,91,572 2019 – 20 12,52,40,878 5,89,107 2020 – 21 11,58,20,929 6,95,649 18. With respect to the addition under section 68 or under section 69C of the learned

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

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

9,40,590 2017 – 18 7,30,88,524 7,76,720 2018 – 19 8,85,94,455 5,91,572 2019 – 20 12,52,40,878 5,89,107 2020 – 21 11,58,20,929 6,95,649 18. With respect to the addition under section 68 or under section 69C of the learned

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

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

9,40,590 2017 – 18 7,30,88,524 7,76,720 2018 – 19 8,85,94,455 5,91,572 2019 – 20 12,52,40,878 5,89,107 2020 – 21 11,58,20,929 6,95,649 18. With respect to the addition under section 68 or under section 69C of the learned

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

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

9,40,590 2017 – 18 7,30,88,524 7,76,720 2018 – 19 8,85,94,455 5,91,572 2019 – 20 12,52,40,878 5,89,107 2020 – 21 11,58,20,929 6,95,649 18. With respect to the addition under section 68 or under section 69C of the learned

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

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

9,40,590 2017 – 18 7,30,88,524 7,76,720 2018 – 19 8,85,94,455 5,91,572 2019 – 20 12,52,40,878 5,89,107 2020 – 21 11,58,20,929 6,95,649 18. With respect to the addition under section 68 or under section 69C of the learned

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

In the result, the appeals of the assessee is allowed

68 was duly submitted before the AO. The AO was duly bond to pass\nan order either granting or rejecting the immunity, penalty levied by AO,\nConfirmed by NFAC CIT (A) in is bad in law.\n3. The learned NFAC CIT (A) Without Jurisdiction erred in concluding that\nInterest paid in excess of Interest received was a shift from sound

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 ()

270A(9)(a) of the Income tax Act, 1961. 3. The Ld. CIT(A) further erred in not considering the fact that, due to an error on the part of the Appellant company, the deduction under Section 80IAC of the Income-tax Act, 1961 was wrongly claimed, when the Appellant company having opted for taxation under Section 115BAA

ATOS INFORMATION TECHNOLOGY HK LTD.,MUMBAI vs. DCIT (INTL. TAX) RANGE 1(1)(2), MUMBAI

Appeals of the assessee are partly allowed for statistical purposes

68 countries with various branches. Under the said 'Cocteau agreement', the role and responsibilities of assessee in respect of providing data processing services has already been discussed in detail in the earlier part of the order including the manner in which the entire processing activity is carried out. The Revenue's case is that first

ATOS INFORMATION TECHNOLOGY HK LTD.,MUMBAI vs. DCIT (INTL. TAX) RANGE 1(1)(2), MUMBAI

Appeals of the assessee are partly allowed for statistical purposes

68 countries with various branches. Under the said 'Cocteau agreement', the role and responsibilities of assessee in respect of providing data processing services has already been discussed in detail in the earlier part of the order including the manner in which the entire processing activity is carried out. The Revenue's case is that first

ATOS INFORMATION TECHNOLOGY HK LTD.,MUMBAI vs. DY CIT (IT)-1 (1)(2), MUMBAI

Appeals of the assessee are partly allowed for statistical purposes

68 countries with various branches. Under the said 'Cocteau agreement', the role and responsibilities of assessee in respect of providing data processing services has already been discussed in detail in the earlier part of the order including the manner in which the entire processing activity is carried out. The Revenue's case is that first

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

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 and remittances were reflected in bank accounts.The assessee also filed additional evidences before

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

9) of ₹ 757,438 by order under section 270A of the act dated 11/1/2022. Prathamesh Vivek Khot; A.Y. 2017-18 06. Assessee preferred an appeal before the CIT appeal, who passed an order on 25/5/2023. With respect to the claim of the immunity, assessee claimed that delay in filing form number 68

PRATHAMESH VIVEK KHOT,MUMBAI vs. INCOME TAX OFFICER NATIONAL E ASSESSMENT CENTRE DELHI, MUMBAI

In the result, appeal of the assessee is allowed

Bench: IN THE INCOME TAX APPELLATE TRIBUNAL, ‘C’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

270A although there was delay in filing Form 68 within the time period. Again the copy of Form 68 was filed before the ld. AO and also before the ld. CIT (A) to grant immunity. However, the ld. CIT (A) held that immunity u/s.270AA can be granted only if the application is made within one month from

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

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

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

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

section 270A(9) so as to deny the benefit of immunity under\nsection 270AA. In absence of any valid rejection of the assessee's application in\nForm No. 68

GENERAL REINSURANCE AG,COLOGNE, GERMANY vs. ASSISTANT COMMISSIONER OF INCOME-TAX (INTERNATIONAL TAXATION) CIRCLE - 2(3)(2), MUMBAI

270A of the Act.”\nITA NO. 4691/Mum/2023 AY 2021-22\n1. On the facts and in the circumstances of the case, and in law, the notice issued\nunder section 143(2) of the Act, dated 27 June 2022, by the Assistant/Deputy\nCommissioner of Income-tax, 1(1)(1), Delhi, to initiate assessment proceedings for\nAY 2021-22, is without

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