In remand, s.14A disallowance cannot exceed original disallowance

Disallowance u/S. 14A cannot not exceed disallowance made in original assessment order if ITAT refer matter back to AO Lld. counsel for the assessee, has submitted that there is no need to remit the matter to the Assessing Officer as the Assessing Officer had not made any dis allowance under Section 14A, except in respect of interest expenditure. He further says that the contention now raised by the revenue does not emanate from the order of the Tribunal. We are not inclined to accept the said contention. We have noted the observations made by the Assessing Officer while making dis allowance u...