2026 (7) TMI 803

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....e Respondent : Shri Ganesh Iyer, Ld. Sr. DR ORDER :: PER, SHRI SONJOY SARMA, JM: Captioned appeal filed by the assessee, pertaining to Assessment Year (AY) 2021-22, is directed against the order under section 250 of the Income-tax Act, 1961 [hereinafter referred to as 'the Act'] passed by the Commissioner of Income Tax(Appeal) [hereinafter referred to as 'Ld.CIT(A)'], dated 30.12.2025, wh....

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....(A). It was contended that while filing the return of income, the assessee had itself made a suo motu disallowance under Section 14A amounting to Rs. 16,347/-. The disallowance was computed at 1% of the annual average of the monthly average opening and closing balances of investments. However, the CIT(A) rejected the contention and upheld the action of the Assessing Officer. 04. Dissatisfied wi....

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....cuments were not considered either by the CPC while passing the order under Section 154 or by the CIT(A) while disposing of the appeal. 05. On the other hand, the Ld. DR relied upon the orders of the lower authorities but could not controvert the factual submissions or the computation placed on record by the assessee. We have heard the rival submissions and perused the material available on rec....