IN THE INCOME TAX APPELLATE TRIBUNAL, ‘E’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER &

SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No.7773/Mum/2025 (Assessment Year :2018-19 Elara Capital (India) Vs. The ACIT-Circle 6(2)(2), Private Limited Mumbai Tower 3, 21st Floor One International Centre Senapati Bapat Marg Elphinstone Road (W)

Mumbai- 400 013 PAN/GIR No.AABCE6487B (Appellant) .. (Respondent Assessee by Shri Milin Dattani a/w. Ms.

Nidhi Jain Revenue by Shri Hemanshu Joshi, Sr.

DR Date of Hearing 05/02/2026 Date of Pronouncement 10/02/2026 / O R D E R आदेश PER AMIT SHUKLA (J.M):

The present appeal has been filed by the assessee against the order dated 24.10.2025 passed by the National Faceless Appeal Centre, Delhi, arising out of the assessment framed under section 143(3) of the Income-tax Act, 1961 for the assessment year 2018-19.

2. The assessee is aggrieved only by the disallowance of ₹39,48,000/- made by the Assessing Officer under section 14A of the Act and sustained by the learned Commissioner (Appeals). It is an admitted and undisputed fact on record that during the year under consideration, the assessee had not earned or received any income which does not form part