ITAT upheld in part the appellate relief to the assessee,...

ITAT upheld in part the appellate relief to the assessee, rejecting the AO's wholesale disallowance of commission expenses where corroborative evidence (account confirmations, PAN/Aadhaar and bank payments) was furnished during appellate proceedings and the AO raised no objections or independent inquiries. Tribunal noted acceptance of similar commission claims in AY 2020-21 and absence of audit/TDS obligation for the preceding year. Finding limited non-compliance (missing identity proof for some recipients), ITAT directed a proportionate disallowance of 15% to safeguard revenue, resulting in an addition of Rs. 13,32,283 and deletion of the remaining Rs. 75,49,603; appeal partly allowed.

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