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Form No. 26AS is relevant evidence of receipts against the...
Form 26AS evidence requires successor-entity accounting verification after business transfer, while invoice-supported related-party advertising expenditure remains allowable.
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Form No. 26AS is relevant evidence of receipts against the deductee's PAN but is not conclusive of income accrual after transfer of the underlying business. Where contemporaneous agreements, reconciliations, non-claim of TDS credit and successor-entity confirmation support the transfer, verification should cover the successor's accounting, assessment of receipts, invoices and TDS credit to prevent duplicate taxation. Advertising expenditure incurred through a holding company may qualify as business expenditure where invoices and published advertisements establish actual services and a direct business nexus. Related-party status, abbreviated invoice particulars, differing advertising rates, or absence of immediate revenue growth do not alone justify full disallowance without identifying an excessive component.
Form No. 26AS is relevant evidence of receipts against the deductee's PAN but is not conclusive of income accrual after transfer of the underlying business. Where contemporaneous agreements, reconciliations, non-claim of TDS credit and successor-entity confirmation support the transfer, verification should cover the successor's accounting, assessment of receipts, invoices and TDS credit to prevent duplicate taxation. Advertising expenditure incurred through a holding company may qualify as business expenditure where invoices and published advertisements establish actual services and a direct business nexus. Related-party status, abbreviated invoice particulars, differing advertising rates, or absence of immediate revenue growth do not alone justify full disallowance without identifying an excessive component.
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