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20% disallowance on site expenses overturned due to lack of evidence from authorities. Additions deleted.

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Full Text of the Document

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....Ad-hoc disallowance @ 20% of total site expenses - none of the authorities below as well as Ld. Sr. DR could bring on record any material to dislodge the claim of the assessee and substantiate the ad-hoc disallowance by adopting a rate of 20% for the same. - Additions deleted - AT....