2019 (2) TMI 1144

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.... For The Respondent : ADVS. SRI. JOSEPH MARKOSE (SR. ) SHRI. ALEXANDER JOSEPH MARKOS SHRI. SHARAD JOSEPH KODANTHARA SRI. ABRAHAM JOSEPH MARKOS 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) whic....

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....nal interfered with the order under Section 263 relying on the decision of the Honourable Supreme Court in (2007) 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 adv....