Held that the Commissioner (Appeals) had correctly observed that not only was the Assessing Officer not justified in adopting a lump sum rate of 2.5 per cent. on payments made to related parties being excessive, as there was no basis or rationale to arrive at such an ad hoc percentage for making disallowance under section 40A(2)(b), but also that the Assessing Officer had not given any specific comparable instance to show that payment made to those parties was not reasonable or not according to prevalent fair market value. The order of the Commissioner (Appeals) in deleting the disallowance was upheld.  (AY.2009-10, 2010-11, 2011-12)