2026 (10) TMI 684

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....2018-19 dated 23.06.2026. 2. The assessee is in appeal before the Tribunal raising the following grounds of appeal: "1. (a) For that on the facts and in the circumstances of the case, the Ld. CIT(A) was unjustified in confirming the AO's action making further disallowance of Rs. 2,65,36,969/- u/s 14A r.w. Rule 8D by applying the machinery computation of Rule 8D(2)(ii) to the average value of the total investments instead of only those investments which actually yielded dividend income during the year. (b) For that on the facts and in the circumstances of the case, the further disallowance of Rs. 2,65,36,969/-made by the AO u/s 14A r.w. Rule 8D was unjustified both on facts and in law and thus deserves to be deleted.....

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....e directly relating to the income which does not form part of the total income at Rs.4,12,184/- and the total disallowance was worked out at Rs.3,77,68,997/-. Since the assessee had already offered an amount of Rs.1,12,32,028/- as disallowance u/s 14A of the Act read with rule 8D of the IT Rules, the remaining amount of Rs.2,65,36,969/- was liable to be disallowed and the total loss was computed at Rs.22,04,66,258/-. Aggrieved with the assessment order, the assessee filed an appeal before the Ld. CIT(A) who considered the submission of the assessee and relying upon the decision in the case of Maxopp Investment Ltd. vs. CIT 402 ITR 640 (SC) and CBDT Circular No. 5/2014 dated 11.02.2014 confirmed the addition and dismissed the appeal of the a....