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while during the A.Y. 2009-10 on a turnover of Rs. 8,91,83,854/-

commission of Rs. 67,82,463/- had been paid, therefore, while the turnover was decreasing year to year payment of commission was increasing. He issued a show cause dated 18/11/2011 and 2/12/2011.

In response to the show cause notice, the appellant had replied, which has been reproduced at page No. 13 to 16 of the assessment order.

Therefore, the ld Assessing Officer disallowed Rs. 43,36,130/- and added back to the total income of the assessee.