assessee to disclose fully and truly all material facts necessary for its
assessment during the year under consideration" would not help. These are
nothing but bald averments. A failure has to be spelt out in the reasons
recorded. Respondents have failed in that. The entire basis for reopening is
that provisions of Section 14A and Rule 8D with regard to dividend income
was attracted but while completing the scrutiny assessment no mention is
made for the same. During the assessment proceedings, after petitioner filed
its revised return of income on 29th March 2014, respondent no.1 issued
notice under Section 142(1) of the said Act on 17th September 2014. Among
other queries, respondent no.1 specifically inquired about the details of
dividend income earned and computation of expenses incurred on earning
this income as per the provisions of Rule 8D. Petitioner, in its reply dated
24th September 2014 to the notice issued under Section 142(1) of the said
Act, has specifically addressed the query with regard to dividend income.
Petitioner has stated that the amount of dividend income is exempt so it is
not included in computation as taxable income. As far as Rule 8D was
concerned, petitioner has submitted that the company is taxable as per the
tonnage tax scheme and thereby, it is not claiming any expenditure, viz.-a-
viz., the exempt income and hence, Rule 8D was not applicable.
