- (1.) This is an appeal against the order of the Tribunal allowing the assessee's appeal by deleting the disallowance made by the Assessing Officer. The matter pertains to the assessment year 2002-03. The Tribunal's order was passed also in ITA No.119 (Asr)/2011 which is the matter relevant to this appeal.
(2.) The following substantial questions of law arise in this appeal:- "(i) Whether on the facts of the case and in law the Hon'ble ITAT was justified in holding that no expense is attributable to the exempted income as the revenue had failed to establish a direct nexus between the expenses incurred and the income earned ignoring that even indirect expenses are attributable u/s 14A as has been made clear by providing for Rule 8D(2) in subsequent assessment years (ii) Whether on the facts of the case the ITAT is right in holding that the legal and professional expenses are allowable ignoring the fact that the assessee has failed to discharge its onus with respect to rendering of services by the payee -
(3.) The assessee are engaged in various activities which they carry on through their different divisions, such as, the packaging, metallise, max foil, pharma, treasury and healthcare divisions.;