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carrying out the disallowance, therefore found no merit in the contentions & relevant ground of the appeal. ITAT-Panaji Page 23 of 42 Prime Mineral Exports Pvt. Ltd.(Now Amalgamated with Fomento Resources Pvt. Ltd.) Vs JCIT, Panaji ITA Nos.003/PAN/2023 AY: 2009-10 5.21 Now coming to alternate plea of the appellant for considering only such investment which yielded exempt income