NOKHA TRADING LLP,BANGALORE vs. DCIT, CIRCLE-1(1)(1), BANGALORE

ITA 2397/BANG/2025Status: DisposedITAT Bangalore19 February 2026AY 2018-19Bench: SHRI PRASHANT MAHARISHI (Vice President), SHRI KESHAV DUBEY (Judicial Member)1 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the dividend income received by the assessee from mutual funds and shares was fully exempt under Sections 10(34) and 10(35) of the Income Tax Act. Therefore, the addition made by the AO and confirmed by the CIT(A) was incorrect, and the deduction under Section 115BBDA was not applicable as the dividend income was not chargeable to tax.

What were the facts?

The assessee, Nokha Trading LLP, filed its return of income for AY 2018-19. The Assessing Officer (AO) completed the assessment but in the computation sheet, a difference arose in the business income. The AO treated dividend income, which was claimed as exempt by the assessee under Sections 10(34) and 10(35), as taxable business income and made an addition.

What were the issues?

Whether dividend income, claimed as exempt under Sections 10(34) and 10(35), could be treated as taxable business income by the AO and whether the consequential addition and deduction under Section 115BBDA were valid.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 144B,Section 10(34),Section 10(35),Section 115BBDA

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH : BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI KESHAV DUBEY

For Appellant: Shri Ankit Marlecha, CA
For Respondent: Shri Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru
Hearing: 17.02.2026Pronounced: 19.02.2026

Per Prashant Maharishi, Vice President

1.

This appeal is filed by Nokha Trading LLP (the assessee/appellant) for the assessment year 2018-19 against the appellate order passed by the National Faceless Appeal Centre, Delhi (NFAC) [ld. CIT(A)] dated 19.8.2025 wherein the appeal filed by the assessee against the assessment order dated 21.6.2021 passed u/s. 143(3) r.w.s. 144B of the Income Tax Act, 1961 [the Act] by the National Faceless Assessment Centre, Delhi [ld. AO] was dismissed.

2.

The assessee has raised the following grounds of appeal :-

“ 1. General Grounds

1.1.

The National Faceless Assessment Centre, Delhi (`A0') h

The order continues below.

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