TMI Blog2019 (2) TMI 1144X X X X Extracts X X X X X X X X Extracts X X X X ..... er Section 263 - HELD THAT:- Whether there should have been an examination on facts, going by the dictum of M/s.S.A.Builders Ltd. [2006 (12) TMI 82 - SUPREME COURT] as to whether there was a commercial expediency insofar as the interest free advances made to the subsidiary company and whether Section 14A could have been applied. We find that the order under Section 263 was passed specifically ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... KOS SRI. ISAAC THOMAS SRI. V. ABRAHAM MARKOS JUDGMENT Vinod Chandran, J . Both the appeals are connected, insofar as the dis-allowance of expenditure having been directed in a proceedings under Section 263 of the Income Tax Act, 1961 ( Act for short) which is challenged in ITA No.1373/2009 and the consequential order is challenged in ITA No.25/2013. 2. The question ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 7) 288 ITR 1 [M/s.S.A.Builders Ltd. v. Commissioner of Income Tax] . 3. The questions arising are two fold. Whether there should have been an examination on facts, going by the dictum of M/s.S.A.Builders Ltd. as to whether there was a commercial expediency insofar as the interest free advances made to the subsidiary company and whether Section 14A could have been applied. We find that the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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