The ITAT upheld the disallowance of business expenditure claimed...

The ITAT upheld the disallowance of business expenditure claimed by the assessee towards payments made to a sister concern for sub-contract execution under section 37. The tribunal concurred with the AO that the assessee failed to provide essential contractual documents, such as a valid contract agreement detailing scope, liabilities, payment terms, and enforceable signatures, thereby undermining the genuineness of the expenditure. The work order submitted lacked critical details of actual work performed and did not establish the assessee or sister concern's role as sub-contractor. The assessee also failed to furnish documentary evidence for third-party verification, reconciliation of payments, and substantiation of claimed amounts, with discrepancies noted between ledger entries and work order values. Given that the claimed sub-contract expenses represented a substantial portion of revenue and total expenses, the lack of adequate documentation raised serious doubts. Consequently, the ITAT found no infirmity in the orders below and dismissed the assessee's appeal.