MANIPAL HEALTH SYSTEMS PRIVATE LIMITED,BANGALORE vs. DCIT, CENTRAL CIRCLE 1(2), BANGALORE

ITA 1092/BANG/2024Status: DisposedITAT Bangalore24 October 2024AY 2018-19Bench: SHRI GEORGE GEORGE K. (Vice President), SHRI LAXMI PRASAD SAHU (Accountant Member)21 pages
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What did the Tribunal hold?

The Tribunal held that the AO must record satisfaction regarding the incorrectness of the assessee's claim before invoking Section 14A. For the back office charges, the Tribunal followed previous decisions in favour of the assessee.

What were the facts?

The assessee claimed no expenditure was incurred for earning exempt income, but the AO invoked Section 14A r.w. Rule 8D, disallowing a portion of expenses. The CIT(A) confirmed the addition. Separately, the revenue appealed against the deletion of disallowance of back office charges paid to a sister concern.

What were the issues?

Whether disallowance under Section 14A is automatic or requires AO's satisfaction, and whether back office charges paid to a sister concern were excessive.

Which sections of the Income-tax Act were involved?

Section 14A,Section 40A(2)

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Cases cited in this judgment(13)Show list

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Income Tax Appellate Tribunal, “B” BENCH : BANGALORE

Before: SHRI GEORGE GEORGE K. & SHRI LAXMI PRASAD SAHU

For Respondent: Shri Subramanian S., Jt.CIT(DR)(ITAT), Bengaluru
Hearing: 01.10.2024Pronounced: 24.10.2024

Per Laxmi Prasad Sahu, Accountant Member The cross appeals for the AY 2014-15 in the case of Mani

The order continues below.

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