2026 (1) TMI 739

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....nafter referred to as 'the Act'). 2. The brief facts of the case are that the assessee had filed its return of income for the A.Y. 2021-22 on 13.03.2022 declaring income of Rs. 16,18,88,82,610/-. The case was selected for complete scrutiny under CASS and the assessment was completed under Section 143(3) of the Act on 30.12.2022 at a total income of Rs. 23,84,69,91,098/-. 3. Aggrieved with the order of the Assessing Officer, the assessee had filed an appeal before the First Appellate Authority which was decided by the Ld. CIT(A) vide the impugned order and the appeal of the assessee was partly allowed. 4. Now the Revenue is in appeal before us. The following grounds have been taken in this appeal: - "1. Whether on the facts....

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....Act read with Rule 8D of the Rules could have made only when the assessee had earned any exempt income during the year. He explained that during the year, no exempt income was earned by the assessee and, therefore, the Ld. CIT(A) had correctly deleted the addition. The ld. AR further submitted that this issue was already covered by the decision of Co-ordinate Bench of this Tribunal in assessee's own case in ITA No.1507/Ahd/2025 dated 16.10.2025. 7. We have considered the rival submissions. We find that this issue was already adjudicated in assessee's own case in ITA No.1507/Ahd/2025. The relevant portion of the said order is reproduced below: - "7. We have considered the rival submissions. There is no dispute to the fact that no....