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Report in that case cannot be correlated with that of the different facts and circumstances in the case of the appellant society. The A.O. has made the addition on estimate basis and not by his specific finding in respect of particular item of expense/purchase as non genuine in the appellant society's case. Further, there is no adverse remark in the audited financial statements by the Auditor of the appellant society for the current assessment year. I find force in the ld. Counsel's submission that since trusts office was running from 31, Shymala Hills, Bhopal, besides the trustees residence, the A.O. had wrongly concluded that the above expenses of Rs. 1,23,217/- are of personal nature for the benefit of Trustees. The addition of Rs.1,23,217/- made by the A.O. is deleted as the A.O. only made the addition on correlation and estimate and neither by specific finding of any particular expense nor substantiated his finding by any supporting voucher expense said to be incurred for the benefit of Trustees of the appellant society. I also rely on the judgment of the Hon'ble jurisdictional High Court in the case of Deo Radha Madhwa Lalji Genda Trust v. Property Tax Officer 251 ITR 531 wherein it was held that maintenance of the trust property, payment to employees and other expenses which are incidental to and connected with the objects of the charitable trust are are decided in favour of the appellant."

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made the addition on co-relation and estimate without bringing any specific finding of any particular expense nor any evidence to substantiate such finding to the effect that the expenses were incurred for the benefit of the trustee of the assessee society, the learned Commissioner of Incometax (Appeals) has deleted the same by relying upon the decision of the jurisdictional High Court in the case of Dev Radha Madhavlal ji Genda Trust; 251 ITR 531 wherein it was held that maintenance of trust property, payment to employees and other expenses are incidental and connected with the objects of the charitable trust. The same, therefore, cannot be disallowed. The learned Commissioner of Incometax (Appeals) has correctly applied the proposition of law as laid down by jurisdictional High Court to the facts of the instant case. No interference is, therefore, warranted in the findings and conclusion