disallowed in respect of Barotiwala Unit during the assessment year 2012-13. Accordingly, show cause notice under Section 263 of the Act was issued on 28.02.2016 by the CIT. After considering the reply filed by the assessee, order under Section 263 of the Act was passed by the CIT on 16.03.2016. Aggrieved by the order, the assessee filed an appeal