Assessee has raised the ground that having regard to the facts and circumstances of thecase, Ld. CIT(A) has erred in law and on facts in not deleting the disallowance made by Ld. AO amounting to Rs. 39,70,224/- (i.e. 30% of Rs. 1,32,34,080/-) on account of commission paid to M/s. Taiyo Enterprises Inc. (NRI) and has erred in enhancing the disallowance by Rs. 92,63,856/- by wrongly observing the commission receipts in the hands of TEI as fee for technical services u/s 9(1)(vii) of the Act read with explanation 2 and further erred in applying the provisions of section 195 and that too without any basis and by recording incorrect facts and findings and without appreciating the facts and circumstances of thecaseand in violation of principles of natural justice and without considering the submission filed by the assessee.