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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.
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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