JUDGMENT :

S.V. Bhatti, J.

We have heard the learned Senior Advocates, Mr. Joseph Markos and Mr. P.K.R. Menon, for the parties.

2. Sahyadri Agencies Limited/assessee is the appellant. The Principal Commissioner of Income Tax, Thrissur/Revenue, is the respondent. The appeal filed under Section 260A of the Income Tax Act 1961 (for short, the Act) arises from the order dated 05.11.2019 in I.T.A. No.439/Coch/2019 of the Income Tax Appellate Tribunal, Cochin Bench (for short, the Tribunal). The controversy relates to the return filed by the assessee for the assessment year 2014-15.

3. The assessee, on 29.09.2014, e-filed the income tax return for the Assessment Year 2014-15. Under Section 143(1) of the Act, the return was processed, and a refund of Rs.6,92,550/- was generated. The return was selected for scrutiny under Computer Aided Scrutiny Selection (CASS) on (i) significant interest expenses relatable to exempt income (under Section 14A) and (ii) substantial interest paid which is not commensurate with the loans raised and that the assessee has returned less turnover. Such scrutiny in the present scenario is known as limited scrutiny. On 25.11.2016, a pre-assessment notice was issued, a