The issue was the subject matter of discussion by the Assessing Officer during the course of assessment proceedings, although, there was no specific discussion in the assessment order. Therefore, revision on this issue was incorrect, because for application of provisions of section 14A of the Act, there should be an exempt income and in this case, exempt income was absent. Therefore, the question of application of provisions of section 14A did not arise. Borrowed money was utilised for the purpose of business, revision is held to be not valid. (AY.2017-18)