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32. The same was upheld by the Ld. CIT(A).

33. Before us, Ld. Counsel for the assessee contended that there was no reason for disallowing these expenses on account of the genuineness of the same as not proved since the assessee had been subjected to internal audit, statutory audit and even audited by the CAG (Comptroller of Auditor General) and nothing to this effect of any ingenuine expenditure having been booked by the assessee was pointed out by Gujarat State Land Development Cor. vs. DCIT any of the auditors. She further contended that this expenditure was being claimed by the assessee year to year and had never been disallowed even in scrutiny assessment. In this regard, our attention was drawn to the submissions made before CIT(A) placed before us at page no. 65 to 75 at para 3.2 and 3.4 are as under:

division officer and it was impracticable to collect and furnish all the details in form of vouchers etc., which are very voluminous in a short time.

3.3 It is further submitted that the books of accounts of head office, division and sub-division are subject matter of internal audit carried out by independent internal auditor, wherein 100% verification of all expenditure incurred by division and sub- division is being carried out by internal auditor. Further, the duty is also caste on internal auditor to carry out physical verification of work done by sub-division. Thus, all the expenditures incurred have been fully verified by independent agency. Inspite of this, the Assessing Officer has made disallowance of 10% of expenditure which is based on presumption and assumption. Further, he has not brought any contrary facts to prove that expenditure is not genuine and therefore, such addition cannot be sustained.

34. Ld. Counsel for the assessee therefore contended that the disallowance to the extent of 10% of the expenses was very high and unfair and prayed that the same Gujarat State Land Development Cor. vs. DCIT may be either be deleted completely or the disallowance be restricted to a smaller amount.

35. Ld. D.R. on the other hand relied on the order of the authorities below.

36. We have heard contentions of both the parties. The issue relates to disallowance of 10% Soil Conservation Expenses for the reason that the assessee failed to produce the vouchers and hence prove their genuineness. No basis, we find, has been stated for disallowing 10% of the expenses and it appears to be totally adhoc. At the same time, it is not denied that the accounts of the assessee are subjected to multiple levels of scrutiny, i.e it is subjected to statutory audit, internal audit and CAG audit and none have reported any such infirmity in the accounts of the assessee in their audit reports. Also these are recurring expenses incurred by the assessee in the course of activities carried out by it. It has been contended before the lower authorities and even before us that no such disallowance was made by the Revenue in the preceding or even succeeding year even in scrutiny assessments. A detail of the impugned expenses incurred from AY 2008-09 to AY 2012-13 was filed before us showing the quantum of such expenses incurred in those years, which we find ranged from 2.85 crores to 5.36 crores, Copies of financial statements of the said years was also filed as evidence . Further assessment orders passed u/s 143(3) of the Act for the said years was also filed showing that except in the impugned year no disallowance was made by the Revenue either in the preceding or succeeding years.