IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “E”, MUMBAI BEFORE SHRI NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER AND SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER ITA No.2586/M/2024 Assessment Year: 2014-15 M/s. HSBC Securities and ACIT 2(1)(2), Capital Markets (India) Private Room No.629, 6^th Floor, Limited, Aayakar Bhavan, Vs.

52/60, Mahatma Gandhi Road, Maharishi Karve Road, Fort, Mumbai Mumbai Maharashtra-400001 Maharashtra - 400020 PAN: AAACJ1395E (Appellant) (Respondent)

Present for:

Assessee by : Ms. Krupa Gandhi, Ld. A.R.

a/w Shri Riken Shah, Ld. A.R.

Revenue by : Shri Biswanath Das, Ld. D.R.

Date of Hearing : 31.01.2025 Date of Pronouncement : 10.02.2025 O R D E R Per : Narender Kumar Choudhry, Judicial Member:

This appeal has been preferred by the Assessee against the order dated 26.03.2024, impugned herein, passed by the Ld. Principal Commissioner of Income Tax (in short Ld. PCIT) under section 263 of the Income Tax Act, 1961 (in short ‘the Act’) for the A.Y. 2014-15.

2. In the instant case, the Assessee had declared its total income at Rs.28,06,90,350/- by filing its return of income on 28.11.2014, which was selected for scrutiny under CASS and ultimately resulted into passing of t