The assessee has questioned first appellate (order) on the (ground) that the learned CIT(A) has erred in facts and law in :

1. confirming the addition of Rs. 17,01,90,088 on account of delay in deposit of employees' contribution to CPF/GPF/ESI under section 36(1)(va);

2. confirming the disallowance of Rs. 2,04,83,00,000 under section 40(a)(ia) in respect of alleged non-deduction of tax at source on transmission/ wheeling/SLDC charges by holding that such payment is liable for deduction of tax at source under section 194J;

2.1. not appreciating the fact that the payment of State Load Dispatch Center charges (SLDC) to RVPN is a statutory levy which is not liable for deduction of tax at source;

2.2. confirming the disallowance under section 40(a)(ia) ignoring the fact that the recipient of the payment (RRVPN) has no income liable to tax and has been assessed by the same AO at nil income;

2.3. not appreciating the fact that payment of wheeling/SLDC charges is nothing but only sharing of cost, i.e., reimbursement of actual expenses to Rajasthan Rajya Vidhyut Prasaran Nigam Ltd., no income is paid and therefore, outside the provisions of Chapter XVII-B of the IT Act, 1