Post-production expenses of feature films are not governed by either under Rule  9A or 9B of the Act. The  assessee having acted as a producer and distributor of a feature film, post-production expenses incurred by him are deductible under s. 37(1) of the Act. Tribunal also held that  since there was no tangible material with the AO to form reasonable belief of escapement of income, except the audit objection on application of Rule  9A and 9B, cannot be said that there was failure on the part of the assessee to disclose fully and truly all facts necessary for completion of assessments, and therefore, the reassessment proceedings were not valid. Tribunal also held that  In the absence of necessary details on record to apply a particular ate for estimation of income from resale of set materials of feature films produced by the assessee, the same is estimated at 5 per cent of total cost incurred on such set materials.  (AY. 2004-05, 2006-07)