The appeals of the assessee are allowed and the appeal of the revenue is dismissed
TDS having been deducted during the year, the expenditure is allowable u/s 40(a). The disallowance is wholly illegal. The same may kindly be directed to be deleted. (12) Pause Ld.CIT (Appeal) has erred in law and on facts in confirming the addition Rs 46, 78, 719/- in respect of non inclusion of other receipt under infrastructure fund. The Ld.CIT