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    <title>2014 (1) TMI 760 - GUJARAT HIGH COURT</title>
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    <description>The consolidated tax appeals involved the disallowance of payments under Section 40A(2)(b) of the IT Act to M/s. Pollucon Engineers. The Assessing Officer disallowed the payments due to perceived excessive amounts, based on the relationship between the payee and the assessee. However, the CIT(A) and ITAT deleted the disallowance, citing lack of evidence for excessive payments and business justifications. The revenue&#039;s appeals challenging the deletions were dismissed, as no substantial legal questions were found, affirming the lower authorities&#039; decisions.</description>
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      <link>https://www.taxtmi.com/caselaws?id=242543</link>
      <description>The consolidated tax appeals involved the disallowance of payments under Section 40A(2)(b) of the IT Act to M/s. Pollucon Engineers. The Assessing Officer disallowed the payments due to perceived excessive amounts, based on the relationship between the payee and the assessee. However, the CIT(A) and ITAT deleted the disallowance, citing lack of evidence for excessive payments and business justifications. The revenue&#039;s appeals challenging the deletions were dismissed, as no substantial legal questions were found, affirming the lower authorities&#039; decisions.</description>
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