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

term capital gains amounting to Rs. 13,46,813/-.\nGROUND NO. II: SHORT GRANT OF CREDIT OF TAX DEDUCTED AT\nSOURCE (“TDS”) AMOUNTING TO RS. 15,76,346/-\n1. On the facts and in the circumstances of the case and in law, CIT(A)\nerred in upholding the action of the AO in granting total credit

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

term capital gains amounting to Rs. 13,46,813/-. GROUND NO. II: SHORT GRANT OF CREDIT OF TAX DEDUCTED AT SOURCE (“TDS”) AMOUNTING TO RS. 15,76,346/- 1. On the facts and in the circumstances of the case and in law, CIT(A) erred in upholding the action of the AO in granting total credit

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

term capital gains amounting to Rs. 13,46,813/-.\nGROUND NO. II: SHORT GRANT OF CREDIT OF TAX DEDUCTED AT\nSOURCE (“TDS”) AMOUNTING TO RS. 15,76,346/-\n1. On the facts and in the circumstances of the case and in law, CIT(A)\nerred in upholding the action of the AO in granting total credit

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

term capital gains amounting to Rs. 13,46,813/-.\nGROUND NO. II: SHORT GRANT OF CREDIT OF TAX DEDUCTED AT SOURCE (“TDS”) AMOUNTING TO RS. 15,76,346/-\n1. On the facts and in the circumstances of the case and in law, CIT(A) erred in upholding the action of the AO in granting total credit

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

short grant of TDS credit. During the hearing, the learned AR submitted that the assessee has filed a rectification application before the AO on 28/10/2025 in this regard, which is still pending consideration. Accordingly, we deem it appropriate to restore this issue to the file of the AO with the direction to grant the credit of taxes deducted at source

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

short grant of TDS credit. During the hearing, the learned AR submitted that the assessee has filed a rectification application before the AO on 28/10/2025 in this regard, which is still pending consideration. Accordingly, we deem it appropriate to restore this issue to the file of the AO with the direction to grant the credit of taxes deducted at source

ISHARES MSCI ALL COUNTRY ASIA EX JAPAN ETF,MUMBAI vs. DCIT (INT. TAX)-2(2)(2), MUMBAI

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

68,24,02,310\nGround of Appeal No. 12: Initiation of penal proceedings under section\n270A of the Act\n12. erred in initiating penalty under section 270A of the Act alleging\nunderreporting of income by the Appellant.”\n40. Ground no.1 is general in nature. Therefore, the same needs no specific\nadjudication.\n41. The issue arising in Grounds no.2-6, raised

DCIT - 19(1), MUMBAI, PIRAMAL CHAMBERS, MUMBAI vs. DISHANT DEEPAK SHAH, MUMBAI

In the result, appeal of the revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17

Short Term Capital Gains and losses on share transactions in listed penny stocks. losses on share transactions in listed penny stocks. losses on share transactions in listed penny stocks. Statements of many entry providers and beneficiaries Statements of many entry providers and beneficiaries Statements of many entry providers and beneficiaries were recorded under section 132(4) and section

LEKHRAJ JASRAJ JAIN ,MUMBAI vs. DCIT 19(1), MUMBAI

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

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2014-15

68 of the Act and of Rs. 1,10,986/- u/s 69C of the Act without providing the appellant a copy of u/s 69C of the Act without providing the appellant a copy of u/s 69C of the Act without providing the appellant a copy of the material and statement relied upon as well as an the material and statement

DCIT, MUMBAI vs. CMS COMPUTERS LIMITED , MUMBAI

In the result, both the appeals of the Revenue are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

short capital loss of Rs.42,83,68,919/- has been adjusted against long term capital gain. Apart from that he noted that similarly Grover family members alongwith 2015 Grover Family Trust had also made investment in JM equity fund against which they have huge dividend and incurred loss on redemption of mutual units. The details of which are as under

DCIT, MUMBAI vs. 2015 GROVER FAMILY TRUST, MUMBAI

In the result, both the appeals of the Revenue are dismissed

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

short capital loss of Rs.42,83,68,919/- has been adjusted against long term capital gain. Apart from that he noted that similarly Grover family members alongwith 2015 Grover Family Trust had also made investment in JM equity fund against which they have huge dividend and incurred loss on redemption of mutual units. The details of which are as under

RAJENDRA KUMAR MUNDRA (HUF),MUMBAI vs. NATIONAL FACELESS ASSESSMENT CENTRE (NFAC), DELHI

In the result the appeal filed by the assessee stands allowed

Bench: Hon’Ble Shri Sandeep Gosain& Shri Girish Agrawalrajendra Kumar Mundra Vs. Ito, Ward 24(3)(1) (Huf) Piramal Chamber C-28, Ameya Bldg, Behind Lalbaug, Mumbai – Ymca Dn Nagar Andheri (W) 400012. 400053. Pan/Gir No.Aadh6828J (Applicant) (Respondent)

short term capital gains disclosed by him to be genuine in the reopened assessment proceedings under section 143(3) read with section 147 of the Act dated 26-5-23. The learned AR placed on record the copy of the said 13 Rajendra Kumar Mundra (HUF)., Mumbai. assessment order in pages 53-56 of the synopsis. This evidence also goes