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7. The operative portion of the Board circular reads (see [1994] 209 ITR (St.) 75) :

"Scope of prima facie disallowance under Section 143(1)(a) of the Income-tax Act, 1961--Clarification regarding.
Section 143(1)(a) authorises, with effect from the 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 (see [1992] 197 ITR (St.) 177), and it has been decided that prima facie disallowances shall be made only in respect of the following types of claims :