Section 14A disallowance and guarantee commission issues were not entertained where factual findings remained unchallenged.

A challenge to disallowance under section 14A was not entertained because the Tribunal's factual finding that the investment was made from the assessee's own funds had not been disputed, so no legal issue arose for reconsideration. The question on guarantee commission was also not entertained because the finding that part of the commission was returned on premature cancellation of guarantees supported recognising the income over the guarantee period. Only question (a) was admitted; questions (b) and (c) were not entertained.

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Issues: Whether the court would entertain the questions relating to disallowance of expenditure under section 14A and taxation of guarantee commission.

Analysis: The objection regarding expenditure linked to exempt dividend income was not entertained because the underlying finding that the investment was made out of the assessee's own funds was a finding of fact not challenged before the Tribunal. The question relating to guarantee commission was also not entertained because the finding that part of the commission was returned on premature cancellation of guarantees supported spreading the income over the guarantee period.

Outcome: Question (a) was admitted, while questions (b) and (c) were not entertained.

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