DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, UDUPI vs. M/S MANIPAL TECHNOLOGIES LIMITED, MANIPAL
In the result, the appeal filed by the Revenue is dismissed
ITA 69/PAN/2018[2013-14]Status: DisposedITAT Panaji15 Jun 2022AY 2013-14
Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2013-14 Dcit, Circle-1, Udupi M/S. Manipal Technologies Limited, Vs. Udayavani Building, Manipal- 576104. Pan: Aabcm 9516 H (Appellant) (Respondent) Present For: Assessee By : Smt. Sheetal Borkar, Advocate Revenue By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 13.06.2022 Date Of Pronouncement : 15.06.2022 O R D E R Per Girish Agrawal: The Present Appeal Filed By The Department Is Arising Out Of The Order Of Commissioner Of Income Tax (Appeals), Mangaluru In Appeal No. Ita No. 10030/Udp/Cit(A)Mng/2016-17 Dated 27.11.2017 Against The Order Of Dcit, Circle- 1, Udupi Passed U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Dated 29.03.2016. 2. There Are Six Grounds Of Appeal Taken By The Department In The Present Appeal, All Of Which Relate To The Disallowance Made U/S 14A Of The Act R.W.R. 8D(2)(Ii) & 8D(2)(Iii) Of The Income-Tax Rules, 1962 (Hereinafter Referred To As ‘The Rules), Amounting To Rs. 1,61,65,201/-.
For Appellant: Smt. Sheetal Borkar, AdvocateFor Respondent: Shri Mayur Kamble, Sr. DR
Section 10(34)Section 115JSection 143(3)Section 14A
29,32,06,800/- made from the own funds of the assessee. Own funds were at Rs.
239,60,57,866/- as on 31.03.2013. It further submitted that no amount was spent to earn the dividend income and hence no disallowance u/s 14A can be made. While completing the assessment, ld. AO relied on various case laws for making
