DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-1(2), BENGALURU vs. MANIPAL EDUCATION AND MEDICAL GROUP INDIA PRIVATE LIMITED, BENGALURU

ITA 2148/BANG/2025Status: DisposedITAT Bangalore25 February 2026AY 2018-19Bench: SHRI PRASHANT MAHARISHI (Vice President), SHRI SOUNDARARAJAN K. (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the disallowance under Section 14A was not sustainable as the Assessing Officer (AO) failed to record the necessary satisfaction regarding the assessee's claim of not incurring expenditure for earning exempt income, and the subsequent addition made by the AO on account of slump sale consideration was also deleted as it was based on the stamp duty value and not the actual consideration received.

What were the facts?

The assessee company, M/s. Manipal Education and Medical Group India Pvt. Ltd., filed cross-appeals against the CIT(A)'s order, which upheld a disallowance under Section 14A of Rs. 75,84,440 and deleted an addition of Rs. 4,44,80,000. The disallowance was related to expenditure incurred for earning exempt income, and the addition was related to the slump sale consideration.

What were the issues?

1. Whether the disallowance under Section 14A is sustainable without proper satisfaction from the AO. 2. Whether the slump sale consideration was correctly determined by the AO.

Which sections of the Income-tax Act were involved?

Section 14A,Section 8D,Section 10(35),Section 50B

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Income Tax Appellate Tribunal, “B” BENCH: BANGALORE

Before: SHRI PRASHANT MAHARISHI & SHRI SOUNDARARAJAN K.

For Appellant: Shri. S. K. Tulsiyan, Advocate
For Respondent: Shri. Subramanian, JCIT(DR)(ITAT), Bengaluru
Hearing: 03.02.2026Pronounced: 26.02.2026

Per Prashant Maharishi, Vice President

1.

Cross appeals are filed in case of M/s. Manipal Education and Medical Group India Pvt. Ltd., (the assessee/appellant) against the order passed by the learned Commissioner of Income Tax-15, Bangalore [learned CIT(A)] on 24.07.2025 wherein the Assessment Orde

The order continues below.

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