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2. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) failed to appreciate the fact that:
a. There are more than one working sites during the year under consideration;
b. The working sites are far from the base of the appellant; and c. There is considerable movement of employees for the management of the works.
3. On the facts and in the circumstances of the case and in law, the Ld. CIT(A) failed to appreciate that the percentage of transportation expense to the turnover has decreased by 1.50% as compared to the previous year.