https://www.taxtmi.com/caselaws?id=202951 An ad hoc disallowance under section 40A(2)(b) cannot be sustained without objective material showing that the related-party payment is excessive or unreasonable, and the addition was deleted for want of such evidence. The amendment to section 40(a)(ia) was treated as clarificatory and retrospective from 1 April 2005 because it was a remedial change intended to remove hardship and align the disallowance rule with deposit of TDS before the return-filing due date under section 139(1). The result was deletion of the disallowance in favour of the assessee. en-us Fri, 03 Dec 2010 00:00:00 +0530 Mon, 19 Jan 2026 10:51:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=202951 An ad hoc disallowance under section 40A(2)(b) cannot be sustained without objective material showing that the related-party payment is excessive or unreasonable, and the addition was deleted for want of such evidence. The amendment to section 40(a)(ia) was treated as clarificatory and retrospective from 1 April 2005 because it was a remedial change intended to remove hardship and align the disallowance rule with deposit of TDS before the return-filing due date under section 139(1). The result was deletion of the disallowance in favour of the assessee. Case-Laws Income Tax Fri, 03 Dec 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=202951