ESJAY COMMERCE LIMITED,KOLKATA vs. DCIT, CIRCLE 7(1),, KOLKATA

ITA 2375/KOL/2025Status: DisposedITAT Kolkata22 July 2026AY 2013-201415 pages
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What were the facts?

The assessee claimed exempt income and made no disallowance under Section 14A. The Assessing Officer (AO) disallowed ₹15,03,485/-. The assessee also incurred lease rent for a property which was rented out, but the AO treated the rental income as income from house property and disallowed the lease rent deduction.

What did the Tribunal hold?

The Tribunal held that the disallowance under Section 14A should be restricted to ₹53,221/- as the assessee's own funds exceeded investments. For the rental income issue, the Tribunal held that lease rent paid is an admissible deduction when computing the annual value of the property as income from house property.

What were the issues?

Whether disallowance under Section 14A is warranted when assessee's own funds exceed investments, and whether lease rent paid is deductible when computing income from house property.

Which sections of the Income-tax Act were involved?

Section 14A,Section 27(iiib),Section 23(1)(b),Section 24

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “A” BENCH, KOLKATA

For Appellant: Shri S.K. Tulsiyan, AR
For Respondent: Shri Sallong Yaden, DR
Hearing: 09.07.2026Pronounced: 22.07.2026

Per Rajesh Kumar, AM:

This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 08.09.2025 for the AY 2013-14. 2. The first issue raised by the assessee in ground no.1 is against the confirmation of disallowance of₹15,03,485/- (wrongly mentioned ₹ 19,10,452/- in the appellate order) by the Ld. CIT (A) as made by the Ld. AO u/s 14A of the Income- tax Act, 1961 (the Act) read with Rule 8D of the Income Tax Rules, 1962 (IT Rules). ESJAY COMMERCE LIMITED; A.Y. 2013-14

2.1.

The facts in brief are that during the course of assessment proceedings the Ld. AO observed that the assessee has ma

The order continues below.

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