Increase in cost of materials consumed due to higher exchange...

Increase in cost of materials consumed due to higher exchange rate for purchases compared to previous year. Adequate explanation provided by assessee regarding increase in ratio of material cost to revenue, overall profitability improvement, and forex rate change details. Ad-hoc addition without examining assessee's submissions cannot be made. Commission expenses increased, assessee provided reasons. Ad-hoc disallowance without finding defects in submissions impermissible. Disallowance u/s 40(a)(ia) incorrect as commission paid to residents, not non-residents. Assessee offered 30% disallowance for non-deduction in return. CIT(A)'s order deleting additions upheld by ITAT.

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