2014 (9) TMI 206

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..... ledge of the AO - It was, thereafter, for the AO to disallow expenditure u/s 14A of the Act – the AO may have erred, but this was not the fault of the assessee or attributable to his failure to disclose full and true material facts - Explanation to Section 147 of the Act would not be applicable - Neither the explanation invoked as the details were per se available and apparent – the order of the T .....

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..... 8377; 51,08,274/- was disallowed after proportionately attributing/bifurcating the expenditure in the ratio of taxable income as shown in profit and loss account and the exempt income. He did not go into any other question and/or justify the basis of the division for any other reason. Before the assessing officer, the respondent/assessee had made an offer that the assessing officer might apply rul .....

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..... t the assessee should not have made full and true disclosure of material particulars. The finding of the Tribunal is that the full and true details of exempt income were clearly stated and mentioned in the return of income and this fact was in the knowledge of the assessing officer in the first/original round. It was, thereafter, for the assessing officer to disallow expenditure under Section 1 .....

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