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    <title>2014 (11) TMI 654 - ITAT JODHPUR</title>
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    <description>Disallowance of JCB hire charges under section 40(a)(ia) failed because the tax had been paid before the return-filing due date and the substituted proviso was treated as curative and retrospective. An ad hoc disallowance of commission expenses also failed because no material showed the expenditure was not for business purposes, so a unilateral estimate was unsustainable. The addition under section 68 on unsecured loans failed because the assessee produced confirmations and affidavits, while the department brought no contrary material to rebut identity and source. The appellate relief was sustained in full.</description>
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      <title>2014 (11) TMI 654 - ITAT JODHPUR</title>
      <link>https://www.taxtmi.com/caselaws?id=253337</link>
      <description>Disallowance of JCB hire charges under section 40(a)(ia) failed because the tax had been paid before the return-filing due date and the substituted proviso was treated as curative and retrospective. An ad hoc disallowance of commission expenses also failed because no material showed the expenditure was not for business purposes, so a unilateral estimate was unsustainable. The addition under section 68 on unsecured loans failed because the assessee produced confirmations and affidavits, while the department brought no contrary material to rebut identity and source. The appellate relief was sustained in full.</description>
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      <pubDate>Tue, 09 Sep 2014 00:00:00 +0530</pubDate>
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