SOCIEADADE DE FOMENTO INDL. PVT. LTD.,MARGAO vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO

In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

2(b) of the assessee are dismissed. 19. Ground of Appeal Nos.3(a) and 3(b) are regarding disallowance under section 14A

ACIT, CENTRAL CIRCLE, PANAJI vs. M/S SOCIADADE DE FOMENTO INDUSTRIAL P. LTD, MARGAO

In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

2(b) of the assessee are dismissed. 19. Ground of Appeal Nos.3(a) and 3(b) are regarding disallowance under section 14A

FOMENTO KARNATAKA MINING COMPANY PRIVATE LIMITED (NOW AMALGAMATED WITH FOMENTO RESOURCES PRIVATE LIMITED,PANAJI vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO

In the result, the appeal filed by the assessee stands partly allowed

Bench: Shri Inturi Rama Rao & Shri Partha Sarathi Chaudhuryआयकर अपील सं. / Ita No.26/Pan/2021 िनधा"रण वष" / Assessment Year : 2009-10 Fomento Karnataka Mining Vs. Jcit, Margao Range, Company Private Limited, Margao, Goa. (Now Amalgamated With Fomento Resources Private Limited), 102, 1St Floor, Kamat Metropolis-I, Behind Caculo Mall, St. Inez, Panaji, Goa- 403001. Pan : Aaacf7487K Appellant Respondent Assessee By : Shri Nishant Thakkar Revenue By : Shri N. Shrikanth Date Of Hearing : 17.08.2023 Date Of Pronouncement : 29.08.2023 आदेश / Order Per Inturi Rama Rao, Am: This Is An Appeal Filed By The Assessee Directed Against The Order Of Ld. Commissioner Of Income Tax (Appeals)-2, Panaji [‘The Cit(A)’] Dated 27.08.2021 For The Assessment Year 2009-10. 2 2. Briefly, The Facts Of The Case Are That The Appellant Is A Company Incorporated Under The Provisions Of The Companies Act, 1956. It Is Engaged In The Business Of Processing & Trading In The Iron Ore. The Return Of Income For The Assessment Year 2009-10 Was Filed On 30.09.2009 Declaring Total Income Of Rs.26,40,77,220/-. Against The Said Return Of Income, The Assessment Was Completed By The Joint Commissioner Of Income Tax, Margao Range, Margao (‘The Assessing Officer’) Vide Order Dated 30.12.2011 Passed U/S 143(3) Of The Income Tax Act, 1961 (‘The Act’) At A Total Income Of Rs.26,63,57,955/-. While Doing So, The Assessing Officer Made Disallowance U/S 14A Of Rs.15,49,787/-, Disallowance On Account Of Sundry Creditors Extracting As Fictitious Of Rs.7,30,948/-. 3. Being Aggrieved, An Appeal Was Filed Before The Ld. Cit(A) Contending That No Disallowance U/S 14A Is Required To Be Made In The Absence Of Any Expenditure Incurred To Earn The Exempt Income. It Was Also Contended That No Addition On Account Of Outstanding Creditors Is Required To Be Made, As The Credits Represent The Opening

disallowance u/s 14A of the Act. The provisions of sub- section (2) of section 14A provides that resort to disallowance

M/S CHOWGULE AND COMPANY (SALT) PVT. LTD,MORMUGAO vs. THE ACIT, CIRCLE - 2, MARGAO

The appeal of the assessee is partly allowed in terms of aforesaid observation

Bench: Shri Ravish Sood & Shri Jamlappa D. Battullआयकर अपील सं. / Ita No. : 390/Pan/2017 करधििाारण वर्ा / Assessment Year : 2012-2013 M/S Chowgule & Company (Salt) Pvt Ltd., Chowgule House, Mormugao Harbour, Goa – 403803. Pan: Aabcc 5595 J . . . . . . . अपीलार्थी / Appellant बिाम / V/S Asstt. Commissioner Of Income Tax, Circle-2, Margao, Goa. . . . . . . . प्रत्यर्थी / Respondent द्वारा / Appearances Assessee By : Ms Hiral Sejpal Revenue By : Shri Sourabh Nayak सुनवाई की तारीख / Date Of Conclusive Hearing : 24/02/2022 घोषणा की तारीख / Date Of Pronouncement : 29/04/2022 आदेश / Order Per Jamlappa D Battull Am; The Present Appeal Filed By The Appellant Assessee Is Directed Against The Order Of Commissioner Of Income Tax- Appeals, Panaji-1 [For Short “Cit(A)”] Dt. 09/10/2017 Passed U/S 250 Of The Income-Tax Act, 1961 [For Short “The Act”], Which In Turn Tousled Out Of Order Of Assessment Of Assistant Commissioner Of Income Tax-Circle-2, Margoa [For Short “Ao”] Dt. 27/07/2014 Passed U/S 143(3) Of The Act, For The Assessment Year [For Short “Ay”] 2012-2013. Itat-Panaji Page 1 Of 23

2) of the Act are debited to the statement of profit and loss account, then only the provisions of section 115JB of the Act would apply. lex lata, the disallowance u/s. 14A

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

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/-.

disallowance under section 14A r.w. Rule 8D is with regard to expenditure under Rule 8D(2)(ii) i.e. expenditure which

M/S. AHILIABAI SARDESSAI, ,PANAJI vs. ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE 1(1), PANAJI

In the result, appeal of assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2015-16 M/S. Ahiliabai Sardessai Assistant Commissioner Of 301, Lotus Court, M. G. Income-Tax, Circle-1(1), Vs. Road, St. Inwz Junction, Panaji. Panaji, Goa-403001. (Pan: Aagfa9044G) (Appellant) (Respondent) Present For: Appellant By : Shri N. J. Prabhudesai, Ar Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 17.06.2022 Date Of Pronouncement : 30.08.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Directed Against The Order Of Ld. Cit(A), Panaji-1 Vide Ita No. Cit(A), Pnj-1/10391/2017-18 Dated 14.09.2018 For A.Y. 2015-16 Passed Against The Assessment Order U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By Acit, Circle-1(1), Panaji, Goa Dated 13.12.2017. 2. Shri N. J. Prabhudesai, Ar Appeared On Behalf Of The Assessee & Shri Mayur Kamble, Sr. Dr Appeared On Behalf Of The Revenue.

disallowance of Rs.5,29,273/- made by the Ld. AO under Rule 8D(2)(iii) of the Income-tax Rules, 1962 (hereinafter referred to as the “Rules”) read with section 14A

ASSTT. COMM. OF INCOME TAX, CENTRAL CIRCLE, PANAJI vs. INFRASTRUCTURE LOGISTICS PVT. LTD., DONA PAULA

In the result, appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 380/Pan/2017 "नधा"रण वष" / Assessment Year : 2009-10 Infrastructure Logistics Pvt. Ltd. Cidade De Goa, Vainguinim Beach, Dona Paula, Goa-403 004. Pan : Aaaci9107R .......अपीलाथ" / Appellant बनाम / V/S. The Joint Commissioner Of Income Tax, Range-1, Panaji-Goa, ……""यथ" / Respondent आयकर अपील सं. / Ita No. 381/Pan/2017 "नधा"रण वष" / Assessment Year : 2009-10 The Assistant Commissioner Of Income Tax, Central Circle, Panaji-Goa, .......अपीलाथ" / Appellant बनाम / V/S.

2. (a) The CIT(A) erred in confirming the disallowance made by the Assessing Officer (AO) under section 14A of the Act read

INFRASTRUCTURE LOGISTICS PVT. LTD.,DONA PAULA vs. JOINT COMM. OF INCOME TAX, RANGE - 1, PANAJI

In the result, appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 380/Pan/2017 "नधा"रण वष" / Assessment Year : 2009-10 Infrastructure Logistics Pvt. Ltd. Cidade De Goa, Vainguinim Beach, Dona Paula, Goa-403 004. Pan : Aaaci9107R .......अपीलाथ" / Appellant बनाम / V/S. The Joint Commissioner Of Income Tax, Range-1, Panaji-Goa, ……""यथ" / Respondent आयकर अपील सं. / Ita No. 381/Pan/2017 "नधा"रण वष" / Assessment Year : 2009-10 The Assistant Commissioner Of Income Tax, Central Circle, Panaji-Goa, .......अपीलाथ" / Appellant बनाम / V/S.

2. (a) The CIT(A) erred in confirming the disallowance made by the Assessing Officer (AO) under section 14A of the Act read

M/S. KINECO (P) LTD.,BARDEZ vs. THE INCOME TAX OFFICER, WARD - 2(4), PANAJI

In the result, appeal of assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2013-14 M/S. Kineco (P) Ltd. Income Tax Officer, Ward- 60, Pilerne Industrial 2(4), Panaji. Vs. Estate, Pilerne, Bardez Goa- 403511. (Pan: Aabcm8681P) (Appellant) (Respondent) Present For: Appellant By : Shri Jitendra Jain, Advocate Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 15.06.2022 Date Of Pronouncement : 30.08.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Directed Against The Order Of Ld. Cit(A)-2, Panaji Vide Ita No. 418/Cit(A)-2/Pnj/2017-18 Dated 01.06.2018 For A.Y. 2013-14 Passed Against The Assessment Order U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By Ito, Ward-2(4), Panaji Dated 22.03.2016. 2. Shri Jitendra Jain, Advocate Appeared On Behalf Of The Assessee & Shri Mayur Kamble, Sr. Dr Appeared On Behalf Of The Revenue.

section 14A of the Act read with Rule 8D(2)(ii) of the Income Tax Rules, 1962 (hereinafter referred to as the “Rules”) of Rs.27,94,090/- and under rule 8D(2)(iii) of the Rules of Rs.1,13,725/-, both totaling to Rs.29,07,815/-. Assessee has raised following three grounds relating to the disallowance

HARDESH ORES PRIVATE LIMITED,MARGAO vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, MARGAO

In the result, appeal of the assessee is partly allowed for statistical purposes

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2012-13 M/S. Hardesh Ores Private Deputy Commissioner Of Limited Income-Tax, Circle-1(1), Villa Flores Da Silva, Vs. Margao, Goa. Erasmo Carvalho Street, Margao, Goa-403601. (Pan: Aaach4515J) (Appellant) (Respondent) Present For: Appellant By : Shri Nishant Thakkar, Advocate Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 16.06.2022 Date Of Pronouncement : 02.09.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Directed Against The Order Of Ld. Cit(A), Panaji-1 Vide

2 M/s. Hardesh Ores Pvt. Ltd. A.Y: 2012-13 (b) The CIT(A) ought to have held that the provisions of section 41(1) are not applicable when in reality there is no remission or cessation of liability by the concerned creditors. 3(a) The CIT(A) erred in confirming the disallowance made by the AO under section 14A

M/S AHILIABAI SARDESSAI,PANAJI vs. ACIT, CIRCLE - 1(1), PANAJI

In the result, appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita Nos. 378 & 379/Pan/2017 "नधा"रण वष" / Assessment Years : 2010-11 & 2012-13 M/S. Ahilibai Sardessai 301, Lotus Court, M.G. Road, St. Inez Junction, Panaji-Goa-403 001 Pan : Aagfa9044G .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(1), Panaji-Goa. ……""यथ" / Respondent Assessee By : Shri D.E. Robinson, Ar Revenue By : Shri Sourabh Nayak, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing :22.02.2022 घोषणा क" तार"ख / Date Of Pronouncement : 31.03.2022

Section 14A(2) and (3) read with Rule 8D of the Rules or a best judgment determination, as earlier prevailing, would become applicable.” Also a similar view had been taken by the Hon'ble Supreme Court in the case of Maxopp Investment Ltd. Vs CIT (2018) 402 ITR 640 (SC). In the case before us, it is a matter

M/S AHILIABAI SARDESSAI,PANAJI vs. ACIT, CIRCLE - 1(1), PANAJI

In the result, appeal of the assessee in ITA No

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita Nos. 378 & 379/Pan/2017 "नधा"रण वष" / Assessment Years : 2010-11 & 2012-13 M/S. Ahilibai Sardessai 301, Lotus Court, M.G. Road, St. Inez Junction, Panaji-Goa-403 001 Pan : Aagfa9044G .......अपीलाथ" / Appellant बनाम / V/S. The Assistant Commissioner Of Income Tax, Circle-1(1), Panaji-Goa. ……""यथ" / Respondent Assessee By : Shri D.E. Robinson, Ar Revenue By : Shri Sourabh Nayak, Sr. Dr सुनवाई क" तार"ख / Date Of Hearing :22.02.2022 घोषणा क" तार"ख / Date Of Pronouncement : 31.03.2022

Section 14A(2) and (3) read with Rule 8D of the Rules or a best judgment determination, as earlier prevailing, would become applicable.” Also a similar view had been taken by the Hon'ble Supreme Court in the case of Maxopp Investment Ltd. Vs CIT (2018) 402 ITR 640 (SC). In the case before us, it is a matter

SHIRDI STEEL RE-ROLLERS PRIVATE LIMITED,CUNCOLIM vs. THE INCOME TAX OFFICER, WARD - 5, MARGAO

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2013-14 Shirdi Steel Re-Rollers Ito, Ward-5, Margao Pvt. Ltd. Nagaraj Kale, Chartered Accountant, G-4, Vs. Kurtarkar Vihar, Opp: Costa Factory, Aquem, Margao, Goa-403601 Pan: Aakfs 3191 G (Appellant) (Respondent) Present For: Appellant By : Shri Srinivas Nayak, Ca Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 16.06.2022 Date Of Pronouncement : 02.09.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Arising Out Of The Order Of Ld. Cit(A),- 2, Panaji In Appeal No. Ita No. 597/Cit(A)-2/Pnj/2017-18 Dated 27.06.2018 Against The Assessment Order Passed By Ito, Ward-5, Margao, U/S 143(3) R.W.S 92Ca Of The Income-Tax Act, 1961 (Hereinafter Referred To As The ‘Act’) Dated 30.12.2018 For A.Y. 2013-14. 2. In The Present Appeal, The Assessee Has Challenged The Additions Made By The Ld. Ao For Four Different Items For Which The Ld. Cit(A) Has Dismissed The Assessee’S Appeal For Non-Prosecution.

disallowance without complying with the requirements of Section 14A to record a satisfaction having regard to the books of account of the assessee. Ld. AO has not brought on record the proximate relationship between the expenditure and the tax exempt income. We note that application of Section 14A read with Rule 8D(2

GANGADHAR NARSINGDAS AGRAWAL (HUF),MARGAO vs. ASSTT. COMM. OF INCOME TAX CIRCLE 1, MARGAO

In the result, appeal of the assessee is allowed

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawalassessment Year: 2011-12 M/S. Gangadhar Narsingdas Assistant Commissioner Of Agrawal (Huf) Income-Tax, Circle-1, 1St Floor, Anand Bhavan, Vs. Margao-Goa. Old Station Rod, Margao- Goa 403601 (Pan: Aabhg4804R) (Appellant) (Respondent) Present For: Appellant By : Shri Nishant Thakkar, Advocate Respondent By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 16.06.2022 Date Of Pronouncement : 30.08.2022 O R D E R Per Girish Agrawal: This Appeal By The Assessee Is Directed Against The Order Of Ld. Cit(A), Panaji-1 Vide Ita No. 42/Mrg/2014-15 Dated 16.03.2018 For A.Y. 2011-12 Passed Against The Assessment Order U/S 143(3) Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By Acit, Circle-1, Margao, Goa Dated 25.03.2014. 2. Shri Nishant Thakkar, Advocate Appeared On Behalf Of The Assessee & Shri Mayur Kamble, Sr. Dr Appeared On Behalf Of The Revenue.

disallowance made under rule 8D(2)(iii) of Rs.10,46,911/- Hon’ble jurisdictional High court of Bomaby, Panaji Bench in CIT Vs. Sociedade De Fomento Industrial Pvt. Ltd. (No. 2) (2020) 429 ITR 358 (Bom.) has held that – “19. Here, on facts, the Tribunal noted that the. Assessing Officer only discussed the provisions of section 14A

SHREE AMBEY FORGING PRIVAT LIMITED,PANAJI vs. ITO, WARD - (4), PANAJI

In the result, both appeals of the assessee are allowed

disallowance made by the AO under section 14A r/w section 8(2)(iii) of Income Tax Rules for a sum of Rs. 14,88,870/- by holding

SCORPIO IRON LTD,PANAJI vs. ITO, WARD - 1(4), PANAJI

In the result, both appeals of the assessee are allowed

disallowance made by the AO under section 14A r/w section 8(2)(iii) of Income Tax Rules for a sum of Rs. 14,88,870/- by holding

THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1 (1), PANAJI., PANAJI vs. M/S ALCON RESORT HOLDINGS PVT. LTD., PANAJI

In the result, appeal filed by the revenue for assessment year 2013-2014

Bench: Shri Shamim Yahya (Am) & Shri Ram Lal Negi (Jm) Assessment Year: 2013-14 The Assistant Commissioner Of Income M/S Alcon Resort Holdings Tax, Circle – 1(1), Pvt. Ltd., 1St Floor, Aayakar Bhawan, Alcon Chambers, Edc Complex, Patto Plaza, Vs. D.B. Road, Panaji, Panaji Goa Pan: Aabca6880E (Appellant) (Respondent) Revenue By : Shri Y.V. Raviraj (Dr) Assessee By : Shri M.C. Naniwadekar (Advocate) Date Of Hearing: 13/11/2018 Date Of Pronouncement: 31/01/2019

2,81,03,292/-, which consisted of business loss of Rs. 1,16,41,586/- and long term capital loss of Rs. 1,64,61,706/-. The assessment order was passed u/s 143 (3) of the Act after making disallowance of unpaid statutory liability u/s 43B amounting to Rs. 71,297/- and disallowance u/s 14A amounting

BANDEKAR BROTHERS PRIVATE LIMITED,VASCO-DA-GAMA, GOA vs. ASSISTANT COMMISSIONER OF INCOME TAX, PANAJI, GOA

The appeal of the assessee is PARTLY ALLOWED in aforestated terms

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2013-14 Bandekar Brothers Pvt. Ltd. Post Box No. 11, Suvarna Bandekar Bldg., Swatantra Path, Vasco-Da-Gama Goa-403802 Pan: Aaacb5502B . . . . . . . Appellant V/S Asstt. Commissioner Of Income Tax, Circle-2(1), Panaji, Goa. . . . . . . . Respondent Represented Assessee By: Mr Pramod & Mr Shriniwas Deshpande [‘Ld. Ar’] Revenue By: Mr M Satish & Mr Renga Rajan [‘Ld. Dr’] Date Of Conclusive Hearing : 12/01/2026 Date Of Pronouncement : 11/02/2026 Order Per G. D. Padmahshali; This Assessee’S Appeal Filed U/S 253(1) Of The Income-

14A of the Act, (b) reversing later two consecutive disallowances made towards construction of roads/temples and disallowance of additional depreciation etc. The Ld. NFAC however, after recording his independent & concurrent findings in line with the findings rendered by the Ld. AO and placing reliance on alike judicial precedents, upheld the disallowance towards ‘stamp duty’ paid to State Government

VEERENDRA BASAVARAJ KOUJALAGI,BELAGAVI vs. PCIT HUBBALLI, HUBBALLI

Bench: Hon’Ble Shri Pavankumar Gadale & Shri G. D. Padmahshaliita Nos. 103/Pan/2024 Assessment Year : 2018-19 Veerendra Basavaraj Koujalagi C/O. Shri Laxmi Complex, Sadashiv Nagar, Belgavi-590001 Pan : Agrpk3086D . . . . . . . Appellant V/S The Pr. Commissioner Of Income Tax, Hubali. . . . . . . . Respondent Appearances Assessee By : Mr Shivanand Halbhavi [‘Ld. Ar’] Revenue By : Capt. Pradeep Arya [‘Ld. Dr’] Date Of Conclusive Hearing : 24/06/2025 Date Of Pronouncement : 28/07/2025 Order Per G. D. Padmahshali; The Assessee’S Captioned Appeal Impugns Din & Order 1063626985(1) Dt. 29/03/2024 Passed By Pr. Commissioner Of Income Tax, Hubali [‘Ld. Pcit’] U/S 263 Of The Income-Tax Act, 1961 [‘The Act’] Which Sought To Revise Order Of Assessment Dt. 26/04/2021 Passed U/S 143(3) R.W.S. 144B Of The Act By National Faceless E-Asstt. Centre, Delhi [‘Ld. Ao’] Anent To Assessment Year 2018-19 [‘Ay’].

section 14A of the Act, therefore there is much less subject/issue to adjudicate on merits in this case. On the other hand both the rival parties are in compelling agreement that, the revisionary action would turn bad in law if the subject matter/issue of disallowance of 14A falls outside the preview of scope of scrutiny assessment. ITAT-Panaji Page