BAJAJ CONSULTANTS PRIVATE LIMITED,MUMBAI vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 4(1), MUMBAI

ITA 2676/MUM/2025Status: DisposedITAT Mumbai09 February 2026AY 2017-18Bench: SHRI OM PRAKASH KANT (Accountant Member), MS. KAVITHA RAJAGOPAL ( (Judicial Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the AO correctly applied Section 14A read with Rule 8D, as the assessee's infrastructure and management were utilized for investment activities. The reliance on own funds versus borrowed funds was deemed irrelevant for the disallowance of administrative and indirect expenses.

What were the facts?

The assessee claimed a suo moto disallowance of Rs. 3,60,748/- under Section 14A read with Rule 8D for expenses incurred to earn exempt income. The Assessing Officer (AO) made a further disallowance of Rs. 36,15,769/-. The CIT(A) confirmed this disallowance.

What were the issues?

Whether the disallowance under Section 14A read with Rule 8D was correctly made by the AO and confirmed by the CIT(A), considering the assessee's suo moto disallowance and the nature of funds used for investments.

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 & MS. KAVITHA RAJAGOPAL

For Appellant: Ms. Srushti Chawda, Shri Leyaqat Ali Aafaqui, Sr. DR
Pronounced: 09/02/2026

PER OM PRAKASH KANT, AM

This appeal by the assessee is directed against order, dated 28.03.2025, passed by the Learned Commissioner of Income Tax (Appeals) – 52 Mumbai [in short ‘the Ld. CIT(A)’] for Assessment Year (in short A.Y) 2017 – 18, raising following grounds:

Bajaj Consultants Private Limited, Bajaj Consultants Private Limited, “The following ground The following grounds of appeal are without prejudice to one another: s of appeal are without prejudice to one another: -

1.

On the facts and the circumstances of the appellant company's case and in law,

1.

On the facts and the circums

The order continues below.

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