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On the contrary, the Ld. DR relied on the order of the lower authorities and submited that Ld. CIT(A) has dealt all the objections of the assessee regarding the dissatisfaction as well as the claim of the assessee of suo-motu disallowance.
Considered for disallownace. Further, regarding the rent for area for disallowed at ₹5,000/- each out of expenses of ₹36,37,338/- and ₹14,66,277/- debited in the profit and loss account under the head 'communication expenses' and 'printing stationery' but no basis of estimate of ₹5,000/- has been provided by the assessee. In the profit and loss account under Note 17 employee benefit expenses have been debited but expenses for staff welfare or other contribution to PF & not another funds and gratuity, have not been considered for disallowance. Similarly, other expenses under Note-19 include electricity expenses, training expenses, travelling and conveyance expenses but same have not been considered for disallowance.
9.1 In view of the above, we do not agree with contention of the Ld. counsel that disallownace has been made on logical and scientific basis. Further, the basis adopted by the assessee is not supported by the documentary evidence. reference to the facts of the said case. Whereas, the instant case,