The Tribunal held that the AO did not record any satisfaction before making the disallowance and merely made the addition because the assessee had earned dividend income. No disallowance be made in the absence of satisfaction that the voluntary disclosure made by the assessee was unreasonable and unsatisfactory. The onus is on the AO to record satisfaction that interest bearing funds used for investment to earn tax-free income. Therefore in the absence of any satisfaction recorded by the AO for  making disallowance no disallowance could be made. (AY.2012-13 to 2014-15)