36(1)(viia) at Rs. 220,50,86,829/- as against allowable claim of Rs. 230,67,63,914/-. 4. Appellant craves to add, amend, alter or modify any of the ground of appeal. 5. The appropriate cost be awarded to the assessee.” 3. Ground no. 1(i) to (iii) are against disallowance made by invoking the provisions of Rule