IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH: BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI PRAKASH CHAND YADAV, JUDICIAL MEMBER ITA No. 2103/Bang/2024 Assessment Year: 2016-17 Mahesh Reddy, Vs. The Income Tax Officer, 21, Embassy Pristine, 6^th Main Road, Ward – 2(3)(4), Iblur Village, Bellandur, Bangalore.

Bangalore – 560 102.

PAN – AFTPR 0449 A APPELLANT RESPONDENT Assessee by : Shri K.R Pradeep, Advocate Revenue by : Shri Subramanian S, JCIT(DR)

Date of hearing : 20.03.2025 Date of Pronouncement : 22.04.2025

O R D E R

PER WASEEM AHMED, ACCOUNTANT MEMBER:

This is an appeal filed by the assessee against the order passed by the NFAC, Delhi dated 18/06/2024 vide DIN No. ITBA/NFAC/S/

250/2024-25/1065707293(1) for the assessment year 2016-17.

2. In the present case, the AO during the assessment proceedings found that the assessee has earned exempted income but the assessee has not made any disallowance under the provisions of section 14A of the Act r.w.r. Rule 8D of Income Tax Rule. Accordingly, the AO invoked the provisions of rule 8D and made the disallowance of ₹ 17,91,403 and added to the total income of the assessee.

3. Aggrieved assessee preferred an appeal to the le