Sec. 14A of Income Tax Act, 1961—Expenditure incurred in relation to income not forming part of total income — It is for the Assessing Officer to establish that the assessee bank has incurred expenditure to earn tax free income and in the assessee bank's case, the Assessing Officer has not established the fact that the assessee bank has incurred any expenditure to earn tax free income - It has not been shown by the AO that any expenditure had been incurred by the assessee for earning its dividend income, merely, an ad hoc disallowance was made and the onus was on the AO to establish any such expenditure and that onus has not been discharged, thus, disallowance deleted - DEPUTY CIT V/s PUNJAB NATIONAL BANK - [2020] 82 ITR (TRIB) 095 (ITAT-DELHI)