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10. While elaborating on a similar provision viz., 143(1)(a) as it existed w.e.f. AY 1989-90, Central Board of Direct Taxes Circular No. 689 dated 24th August 1994 (209 ITR Statute 75) observed as follows:

" Section 143(1)(a) authorises, with effect from assessment year 1989-90, inter alia, disallowance of any loss carried forward, deduction, allowance or relief claimed which, on the basis of information available in the return or the accompanying accounts or documents is prima facie inadmissible. The earlier instructions of the Board were to the effect that no disallowance should be made of items on which two opinions are possible. The matter has been further considered by the Board in the light of the recommendations of the "Tax Reforms Committee" headed by Prof Raja J. Chelliah and it has been decided that prima facie disallowance shall be made only in respect of following types of claims :