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Issues: (i) Whether disallowance under Section 14A of the Income-tax Act, 1961 was warranted in the facts of the case; (ii) whether the second proviso to Section 40(a)(ia) of the Income-tax Act, 1961 applied to Assessment Year 2010-11.
Issue (i): Whether disallowance under Section 14A of the Income-tax Act, 1961 was warranted in the facts of the case.
Analysis: The issue was treated as covered by prior decisions of the Court, including the later decision in Mcdonalds's India (P.) Ltd., which had decided the point against the Revenue.
Conclusion: The issue was decided against the Revenue.
Issue (ii): Whether the second proviso to Section 40(a)(ia) of the Income-tax Act, 1961 applied to Assessment Year 2010-11.
Analysis: The issue was treated as covered by the Court's earlier decision in Ansal Land Mark Township (P.) Ltd., which had decided the point against the Revenue.
Conclusion: The issue was decided against the Revenue.
Final Conclusion: As both issues were covered by binding precedent and no substantial question of law arose, the appeal was dismissed.
Ratio Decidendi: Where the questions raised are already concluded by binding precedent, no substantial question of law arises in the revenue appeal.