Disallowance under s.40A(2)(b) for purchases from a related...

Disallowance under s.40A(2)(b) for purchases from a related concern was held unsustainable because the AO produced no comparables to show the price paid was excessive or unreasonable; since the assessee purchased at the same (discounted) price as the group concern, the disallowance was deleted. Addition for cash deposits during demonetization was partly sustained because the assessee failed to fully evidence accumulation of cash gifts, but considering status and reasonableness, 50% relief was upheld and the balance treated as unexplained. Disallowance of cost of improvement was deleted as expenditure and sources were supported by additional evidence, banking-channel payments, joint ownership funding, and confirmations, with no infirmity shown. - ITAT