2025 (3) TMI 2065

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....r Aggarwal, Adv For the Revenue : Sh. Sahil Kumar Bansal, Sr. DR ORDER PER YOGESH KUMAR, U.S. JM: The present appeal is filed by the Assessee against the order of the Commissioner of Income Tax Appeal/national e-Assessment Centre, Delhi, dated 29/03/2024 for the Assessment Year 2018-19. 2. The Grounds of appeal are as under:- "1. That the learned CIT Appeal are not justifie....

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....investment was made in F.Y. 17-18, in mutual funds, as it is old investment of previous years, and as such section 14A is not applicable and the disallowance of Rs. 19,59,420/- for A.Y. 18-19 is wrong, unjustified and is illegal." 3. Brief facts of the case are that, the Assessee filed return of NIL income claiming current year loss of Rs. 1,27,39,983/-. The assessment was completed u/s 143(3) ....

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....e disallowance made u/s 14A of the Act. 5. Per contra, the Ld. Departmental Representative submitted that the Assessee has not produced any submission/documentary evidence in support of the Grounds of Appeal before the Ld. CIT(A), therefore, the Appeal of the Assessee has been rightly dismissed by the Ld. CIT(A). Therefore, relying on the orders of the Lower Authorities, sought for dismissal of....

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....ule 14A of the Act at Rs. 1,87,700/-, accordingly, made addition of Rs. 19,59,420/-. In the order of the Ld. CIT(A) it has been observed that the Assessee had not filed any submission/documentary evidence in support of Grounds of Appeal. It was the case of the Assessee regarding disallowance of Rs. 19,59,420/- made by the A.O. u/s 14A r.w. Rule 8D of the Income Tax, that no investment was made dur....