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TMI Blog2024 (11) TMI 1317X X X X Extracts X X X X X X X X Extracts X X X X ..... assessee, challenging the order of the learned Commissioner of Income Tax (Appeals) ('ld.CIT(A) for short),National Faceless Appeal Centre ('NFAC' for short) passed u/s. 250 of the Income Tax Act, 1961 ('the Act'), pertaining to the Assessment Year ('A.Y.' for short) 2021-22. 2. The assessee has raised the following grounds of appeal: 1. That on the facts and in the circumstances of the ca ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... r 1 April 2022. The above grounds of appeal are all independent and without prejudice to one another. The Appellant craves leave to supplement, rescind, amend, add and or otherwise alter/modify any or all the grounds of the appeal stated hereinabove, either before or at the time of hearing of this appeal The Appellant prays that the Ld. CIT(A) be directed to grant relief in respect of the Grou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and on account of ESOP expenses. 4. The assessee was in appeal before the first appellate authority, challenging the assessment order. 5. The ld. CIT(A) vide order dated 28.06.2024, partly upheld the order of the ld. A.O. and confirmed the disallowance made u/s. 14A of the Act. 6. The assessee is in appeal before us, challenging the impugned order of the ld. CIT(A). 7. The learned Authorised ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2020] 121 taxmann.com 177 (Bombay HC) e. ACIT vs. Direct Media Distribution Ventures (P.) Ltd. [2023] 148 taxmann.com 35 (Mumbai Tribunal). 8. The learned Departmental Representative ('ld.DR' for short) on the other hand controverted the said fact and relied on circular no. 5/2014 which emphasizes that disallowance u/s. 14A of the Act is warranted even when no exempt income has been ear ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at disallowance u/s. 14A is to be made even when the assessee has not earned any exempt income and the same has been reiterated by the decision of the Hon'ble Delhi High Court in the case of PCIT vs. Era Infrastructure (India) Ltd. [2022] 141 taxmann.com 289 (Delhi HC) which has been followed in various other subsequent decisions. 10. On the above factual matrix of the case, we are of the conside ..... X X X X Extracts X X X X X X X X Extracts X X X X
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