आदेश / O R D E R

PER AMIT SHUKLA (J.M):

The aforesaid appeal has been filed by the assessee against the impugned order dated 04.12.2025 passed by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, arising out of the assessment order passed under section 143(3) of the Income Tax Act, 1961 for the Assessment Year 2014-15.

The sole grievance raised by the assessee in the present appeal relates to the disallowance of ₹6,23,736 made under section 14A read with Rule 8D of the Income Tax Rules, 1962 and sustained by the learned CIT(A).

Briefly stated, the facts borne out from the assessment records are that the assessee is an individual engaged in business activities through two proprietary concerns, namely M/s. Chic Baby and M/s. Duru Realty. The return of income was originally filed on 29.07.2014 declaring total income of ₹4,90,000. Subsequently, a revised return was filed declaring income of ₹54,55,448. During the course of scrutiny assessment proceedings, the Assessing Officer observed that the assessee had earned exempt income comprising dividend income of ₹1,85,455 and long-term capital gains amounting to ₹6,86,351. The Assessing Officer furt