Disallowance u/s 14A Rs.8,74,323/- (f) Interest on diversion of funds Rs.10,95,150/- (g) Land Restoration expenses Rs.1,07,375/- (2) The ld. CIT(A) erred in not appreciating the fact that the assessee failed to substantiate the reasons for making wrong claim in the returned income in terms of Clause (B) to Explanation 1 of Section