Dismissing the petition the Court held, that it had been articulated in the reasons recorded for issuing the notice under section 148 that disallowance under section 14A of the Act should be made as per the methodology prescribed in rule 8D of the Income-tax Rules, 1962, and that section 14A read with rule 8D was not adhered to by the assessee in computation of income. Therefore, this matter turned on the facts. The assessee bank itself made a disallowance to the tune of over 69.23 lakhs under section 14A and in that context there was a reference to section 14A read with rule 8D. It was also made clear that disallowance of interest or expenditure ought to have been computed at a particular quantum whereas the assessee bank had disallowed an amount of only Rs. 69.23 lakhs and odd. Whether these needed to be disallowed was the point raised. All this turned heavily on the facts. In other words, these were all questions of fact. Hence a writ would not issue to quash the notice. (AY.  2014-15)