ITAT cannot remand to apply section 14A if AO in his Assessment order not made disallowance u/s 14A

In assessment proceedings, the AO raised a query about dis allowance of expenditure attributable to exempted dividend income u/s 14A. After considering the assessee’s reply, no dis allowance was made u/s 14A, though interest expenditure was disallowed on the ground that it was not for business purposes. This was confirmed by the CIT (A). On appeal by the assessee, the Tribunal remanded the matter to the AO by observing that the AO should reconsider the matter in the light of Daga Capital Management 199 TTJ 289 (SB) (Mum). On appeal by the assessee, HELD: As the AO had not made any dis allowa...