Court held that  the Dispute Resolution Panel as well as the Tribunal had failed to consider the contentions raised by the assessee as to how section 14A read with rule 8D(2)(ii) was not attracted. Therefore, there was a factual error. The Assessing Officer was to decide whether it was correct to have disallowed the interest on debentures under section 14A when the assessee’s contention was that the interest expenditure was incurred on debentures issued in the financial year 2008-09 for the specific purpose of acquiring the company in the past and not for investment in future. Furthermore, the Assessing Officer was to consider the submission of the assessee that the interest incurred by it was specifically towards acquisition of shares in the company which was subsequently amalgamated with the assessee and such amalgamation was approved by the court with effect from April 1, 2008. The matter was remanded to the Assessing Officer to decide afresh. (AY. 2012-13) (Maxopp Investment Ltd. v. CIT (2018) 402 ITR 640 (SC) referred)