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The ITAT reversed the disallowance of interest/compensation under section 69C and application of tax rate under section 115BBE. The Tribunal held that payments made according to business agreements cannot be deemed bogus or non-business related without adverse evidence. The authorities failed to consider relevant records before making their determination. The Tribunal clarified that section 69C (unexplained expenditure outside books) was improperly invoked since the assessee had properly recorded and claimed the payment as an expenditure in profit and loss accounts. The addition was deleted and the assessee's appeal was allowed.
The ITAT reversed the disallowance of interest/compensation under section 69C and application of tax rate under section 115BBE. The Tribunal held that payments made according to business agreements cannot be deemed bogus or non-business related without adverse evidence. The authorities failed to consider relevant records before making their determination. The Tribunal clarified that section 69C (unexplained expenditure outside books) was improperly invoked since the assessee had properly recorded and claimed the payment as an expenditure in profit and loss accounts. The addition was deleted and the assessee's appeal was allowed.
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