Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

80D only if he is not satisfied with correctness of claim of the assessee, that too, after having regard to accounts of assessee-In instant cases, assessee is putting forth its contention against disallowance from different angles-Some of contentions were raised for first time before Tribunal-Contentions of assessee can be appreciated only if relevant facts are available