BARCLAYS BANK PLC,MUMBAI vs. CIT (INTERNATIONAL TAXATION)-RANGE-1, MUMBAI

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

Bench: Shri Shamim Yahya (Am) & Shri Amarjit Singh (Jm)

Properties v. Director of Income-tax [1996] 57 lTD 328 (Bombay,) wherein the Tribunal upheld the argument of the assessee that when an order is passed by the Assessing Officer pursuant to the directions of a superior authority, the same could not be the subject matter of revision under section 263 of the Act. 1.6. The appellant submits that

THE INDIAN HOTELS CO. LTD.,MUMBAI vs. PR. CIT-1, MUMBAI

In the result, the appeal of the assessee is hereby allowed

Bench: Shri Amarjit Singh, Jm & Shri S. Rifaur Rahman, Am आयकर अपील सं/ I.T.A. No.950/Mum/2021 (ननधधारण वर्ा / Assessment Years: 2014-15) बनधम/ The Indian Hotels Company Pcit-1 Room No.330, 3Rd Floor, Ltd. Vs. 9Th Floor, Express Towers, Aayakar Bhavan, Barrister Rajini Patel Marg, Maharishi Karve Road, Nariman Point, Mumbai- Mumbai-400020. 400021. स्थधयी लेखध सं./जीआइआर सं./Pan/Gir No. : Aaact3957G (अपीलाथी /Appellant) (प्रत्यथी / Respondent) .. Assessee By: Shri K. K. Ved Revenue By: Shri Surendra Kumar (Dr) सुनवाई की तारीख / Date Of Hearing: 17/03/2022 घोषणा की तारीख /Date Of Pronouncement: 12/04/2022 आदेश / O R D E R Per Amarjit Singh, Jm: The Assessee Has Filed The Present Appeal Against The Order Dated 31.03.2021 Passed By The Principal Commissioner Of Income Tax-01, Mumbai [Hereinafter Referred To As The “Pcit”] Relevant To The A.Y.2014-15 In Which The Principal Commissioner Of Income Tax-01 Has Invoked The Revisional Power U/S 263 Of The I.T. Act, 1961. 2. The Assessee Has Raised The Following Grounds Of Appeal: - “Re.: Validity Of Order U/S, 263; On The Facts & In The Circumstances Of The Case & In Law, The Impugned Order Dated 31 March 2021 Passed Under Section 263 Of The Act Is Without Jurisdiction & Bad In Law. Without Prejudice To The Above, On The Facts & Circumstances Of The Case & In Law, The Principal Commissioner Of Income Tax (“Pcit”) Has Erred In Passing The Order Dated 31 March 2021 U/S. 263 Of The Act.

properties is generally provided through in room television set and the advertisement / article in the Taj magazine / Coffee Table magazine kept in the rooms of overseas hotel units. - It is further submitted that in competitive industry like hospitality, apart from retaining existing customers, it is must to reach out the customers to widen its customer base in best possible manner

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(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(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

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 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 MSCI EM UCITS ETF USD DIST ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION)-2(2)(2), MUMBAI

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.\n\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

ISHARES MSCI INDIA UCITS ETF ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX (INTERNATIONAL TAXATION )-2(2)(2), MUMBAI

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.\n\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