Bench: Shri Aby.T Varkey & Shri Waseem Ahmedassessment Year:2009-10 Dcit, Circle-4, Kolkata V/S. M/S Rossell India Ltd. P-7, Chowringhee 21/1A/3, Darga Road, Square, Kolkata-69 Jindal Towers, Block B, 4Th Floor, Park Circus, Kolkta-700 017 [Pan Noaabcr 3736 J] .. अपीलाथ" /Appellant ""यथ"/Respondent

sections (2) and (3) of sec. 14A and Sub-rule(l) of Rule 80, assessing officer had rightly invoked the said Rules for determining that portion of interest which is to be disallowed u/s 14A. Ld. CIT(A)'s observation was not correct more so when no opportunity was allowed to A.O. under Rule 46A to examine the fresh submission