Please take this as advice, not criticism

MOV DPTR,#0010H ;LOAD DPTR   the kind of 'comment' that makes no sense
MOV R0,#40H ;IRAM BACKUP PTR very good
MOV R1,#50H ;IRAM PTR        ptr to what
MOV R7,#16 ;COUNT=16         count of what

Re the first comment "makes no sense": the purpose of a comment is to comment what you are doing, not what the instruction does. If someone need that type of comments, they should not attempt to read the code anyhow.

Erik