Held that the jurisdictional pre-condition as laid down in provisions of section 14A(2) of the Act was not fulfilled. Further, the disallowance of Rs. 3 lakhs computed by the Dispute Resolution Panel was not by applying the mandatory computation provisions of rule 8D of the Income-tax Rules, 1962 but merely as a reasonable disallowance under section 14A(1) of the Act. Therefore, there was no basis to uphold the disallowance made under section 14A of the Act. (AY.2009-10, 2010-11)