The correct option is A for tetrahedral complexes, the CFSE is lower than pairing energy.
Low spin tetrahedral complexes are not formed because the crystal field stabilisation energy for tetrahedral complexes is less than pairing energy.
Because, only four ligands instead of six (octahedral) in involved in tetrahedral complex formation, so the ligand field is only two-third the size of octahedral splitting. The direction of the orbitals also does not coincide with the direction of the ligands in tetrahedral.
As a result tetrahedral splitting Δt is always much smaller than the octahedral splitting Δo.
Also in tetrahedral, it is never energetically favourable to pair electrons.
Hence, electons does not pair up to form low spin complexes and gives only high spin complex.