The learned Commissioner of Income-tax Officer (Appeals) [hereinafter referred to as CIT(A)) and the Assessing Officer thereinafter referred to as the AO] failed to appreciate that the Appellant Company had on its own, offered Rs. 17 lakhs as disallowance u/s.14A, being Operating & Administrative Expenses and Establishment / General Expenses, which could be considered as attributable towards earning exempt dividend income. The CIT(A) has disallowed 0.5% of average investments (excluding Investments which yielded taxable income), which is unwarranted.The Appellant Company therefore prays that the additional disallowance made by the CIT(A), over and above the disallowance of Rs. 17 lakhs voluntarily offered by the Appellant Company be deleted.