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TMI Blog2017 (5) TMI 843X X X X Extracts X X X X X X X X Extracts X X X X ..... nder section 14A was restricted to the amount of exempt income only and not at a higher figure. Once that was so, we do not consider it appropriate to discuss the scope of section 263 of the Act as the same has been rendered academic in view of the issue being answered in favour of the assessee on the merits. Thus, no substantial question of law arises. Consequently, the appeal stands dismissed. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... aw in quashing the order under section 263 of the Income-tax Act, 1961 without considering the observations made by the Commissioner of Income-tax in that ORDER ? 2. Briefly, the facts necessary for adjudication of the controversy involved, as narrated in appeal, may be noticed. During the assessment proceedings under section 143(3) of the Act, vide order dated December 23, 2011, the Ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s made by the Assessing Officer. After considering the assessee's reply, the Commissioner of Income-tax, (CIT), vide its order dated March 18, 2014 enhanced the disallowance to ₹ 45.76 crores and directed the Assessing Officer to pass an order accordingly. Aggrieved by the order, the assessee filed an appeal before the Tribunal. Vide order dated March 28, 2016, annexure A.3, the Tribunal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Learned counsel relied upon the decision of a Division Bench of this court in Principal CIT v. State Bank of Patiala [2017] 391 ITR 218 (P H) ; [2017] 78 taxmann.com 3 (P H), in the case of the assessee relating to the assessment year 2008- 09 wherein the issue on the merits has been answered in favour of the assessee and against the Revenue. The appeal in the said case was accordingly dismissed. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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