NUVAMA WEALTH MANAGEMENT LIMITED,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX-1(1), MUMBAI

ITA 6760/MUM/2025Status: DisposedITAT Mumbai27 February 2026AY 2014-1513 pages
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What did the Tribunal hold?

The Tribunal held that the AO had recorded sufficient dissatisfaction to invoke Section 14A and Rule 8D. The disallowance under Rule 8D(2)(iii) should be computed considering only investments that yielded exempt income.

What were the facts?

The assessee, engaged in share broking and investment, made a suo motu disallowance under Section 14A. The Assessing Officer (AO) found this inadequate and computed a higher disallowance. The CIT(A) restricted the disallowance to the extent of exempt income.

What were the issues?

Whether the AO recorded sufficient dissatisfaction to invoke Section 14A and Rule 8D, and how the disallowance under Rule 8D(2)(iii) should be computed.

Which sections of the Income-tax Act were involved?

Section 14A

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Income Tax Appellate Tribunal, MUMBAI BENCH “B” MUMBAI

Before: SHRI OM PRAKASH KANT (ACCOUNT MEMBER) & MS. KAVITHA RAJAGOPAL

For Appellant: Shri Ravikant Pathak
For Respondent: Shri Leyaqat Ali Aafaqui, Sr. DR
Hearing: 23/12/2025Pronounced: 27/02/2026

PER OM PRAKASH KANT, AM These two appeals by the assessee are directed against two separate orders, both dated 20th August, 2025 passed by the Ld. Commissioner of Income Tax (Appeals) 47, Mumbai [in short, “the Ld. CIT(A)] for assessment years 2014-15 and 2015-16 respectively.

2.

In both these appeals, identical issue in dispute of disallowance u/s 14A of the Act is involved and, therefore, both these appeals were heard together and disposed off by way of this consolidated order for the sake of convenience.

3.

Now, we take up the appeal of the assessee for

The order continues below.

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