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2.2 Aggrieved, the assessee is now before the ITAT and has challenged the action of the Ld. CIT (A) in upholding the additions disallowance by raising the following grounds of appeal:

1. "That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AR in making disallowance of Rs. 2,26,500/- on account of ROC fees.

2. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in making disallowance of Rs. 26,22,677/- on account of expenditure claimed in profit & loss account on the ground that no business activity was carried out and impugned disallowance has been made by recording incorrect facts and findings and without observing the principles of natural justice and further erred in making double disallowance to the extent of Rs.

2,26,500/- relating to ROC fees.

3. That having regard to the facts and circumstances of the case, Ld. CIT(A) has erred in law and on facts in confirming the action of Ld. AO in making aggregate M/s. JRG Holdings (P) Ltd. vs ITO addition of Rs. 2,90,27,890/- on account of deemed dividend u/s 2(22)(e), more so when the same was in the nature of inter corporate deposits and impugned addition has been made by recording incorrect facts and findings and without observing the principles of nature justice and without complying with the other mandatory conditions for applicability of section 2(22)(e) of Income Tax Act, 1961 and judicial decisions rendered in this regard.

was subsequently repaid to M/s. Mega Trading Corporation further evidencing the genuineness of the transaction.

3.4 The Ld. AR also filed a brief synopsis relating to the grounds raised by the assessee and the same is reproduced hereunder for ready reference:-

"GROUND NO.1 is regarding the disallowance of Rs. 2,26,500/- on account of ROC fee, which has been confirmed by Ld. CIT(A).

Ld. A.O. has discussed this issue at page----2 of the assessment order, whereas Ld. CIT (A) has discussed this issue at page 43-44 of the appeal order.

It was submitted before both Ld. A.O. and Ld. CIT(A) that amount of Rs. 2,26,500 includes an amount of Rs. 5,5001- paid as fees for filing of Annual Return with ROC, which under no circumstances can be disallowed.

PB 67-73 is assessee's reply dated 08-11-2016 filed to Ld. AO wherein at page 73 details of Rs.2,26,500 has been given which includes Rs.5,500 towards ROC filing fees.

PB 67-73 is the copy of assesee's letter to Ld. A.O. submitting inter alia the details of ROC fee consisting of Rs. 5,5001- at PB 73.