IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER AND SHRI MAKARAND VASANT MAHADEOKAR, ACCOUNTANT MEMBER ITA No. 5843/MUM/2025 (AY: 2013-2014)

(Physical hearing)

Mirchandani & Company Private Assistant Commissioner of Limited Vs Income Tax, Circle 5(2)(1), Maharashtra 400026 Mumbai, Aayakar Bhavan, [PAN: AAACM2811J] M.K. Road, Mumbai, Maharashtra 400020 Appellant / Assessee Respondent / Revenue Assessee by Shri Rajiv Khandelwal, CA Revenue by Shri Usha Gaikwad - Sr. DR Date of hearing 16.03.2026 Date of pronouncement 14.05.2026 Order under section 254(1) of Income Tax Act PER PAWAN SINGH, JUDICIAL MEMBER:

1. This appeal by assessee is directed against the order of ld. CIT(A) dated

20.12.2024 for Assessment Year 2013-14. The assessee has raised following grounds of appeal:

i. The Additional Commissioner of Income-tax (Appeals) (hereinafter referred to as the Addl. CIT(A)) erred in upholding the action of the Assistant Commissioner of Income-tax 5(2)(1), Mumbai (hereinafter referred to as the Assessing Officer) in making a disallowance of a sum of Rs 21,13,919 on account of expenses incurred for earning income which does not form part of the