2026 (9) TMI 29

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....ra, Sr Dr ORDER PER MANISH AGARWAL, A.M.: The present appeal is filed by assessee against the order dated 25.11.2025 passed by Ld. Commissioner of Income Tax (A), National Faceless Appeal Centre ("NFAC"), Delhi ["Ld. CIT(A)"] in Appeal No. NFAC/2016- 17/10445200 u/s 250 of the Income Tax Act, 1961 ["the Act"] arising out of assessment order dated 13.02.2025 passed u/s 147 r..w.s. 144 r.w.....

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....rder passed u/s 143(3) of the Act on 17.12.2019 by making disallowance of INR 50,67,402/- on account of amortization premium paid on HTM securities. Thereafter, based on the audit objection raised by the internal team of the department, re-assessment proceedings were initiated by issue of notice u/s 148A of the Act, stating that the assessee has made investments in the securities having exempt inc....

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....lue of the investment made having exempt income. 3. Against the said order, appeal was filed before ld. CIT(A) wherein reliance was placed on the judgement of Hon'ble Supreme Court in the case of PCIT vs Oil Industry Development Board [2019]. However, ld. CIT(A) following the amendment made in section 14A w.e.f. 01.04.2022 applicable from AY 2022-23 and onwards according to which disallowance u....

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....tle "dividend income" "NIL income" was declared. It is further observed that this issue was examined during the course of assessment proceedings concluded u/s 143(3) and after considering the fact that no exempt income was declared, no disallowance was made u/s 14A of the Act. However, in the reassessment proceedings despite of the fact that the assessee has specifically stated that it has no exem....