disallowing @40%, the expenses on the same?” 21. Learned Standing Counsel Sri.Y.V.Raviraj has facilitated the order of the ITAT in IT(TP) A No.182 (Bang) 2014 of the assessment year 2009-10, wherein the ITAT has held that the assessee’s appeal directed against the assessment order passed by the A.O. under Section 144C (13) as per the directions