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    <title>2018 (11) TMI 1902 - ITAT KOLKATA</title>
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    <description>Disallowance of commission expenditure and annual maintenance service expenses was held unsustainable where the assessee substantiated the payments with agreements, invoices, confirmations, bank records, PAN and tax details, TDS particulars, and lower-deduction certificates under section 197(1). The Tribunal noted that the Revenue identified no specific defect in the evidence and did not show any routing back of funds. Mere failure of the payees to respond to notices under section 133(6) was insufficient to reject otherwise supported business expenditure, particularly when the related sales and service receipts were accepted and the commercial need for the arrangements was evident. The disallowance was deleted.</description>
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      <title>2018 (11) TMI 1902 - ITAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=302484</link>
      <description>Disallowance of commission expenditure and annual maintenance service expenses was held unsustainable where the assessee substantiated the payments with agreements, invoices, confirmations, bank records, PAN and tax details, TDS particulars, and lower-deduction certificates under section 197(1). The Tribunal noted that the Revenue identified no specific defect in the evidence and did not show any routing back of funds. Mere failure of the payees to respond to notices under section 133(6) was insufficient to reject otherwise supported business expenditure, particularly when the related sales and service receipts were accepted and the commercial need for the arrangements was evident. The disallowance was deleted.</description>
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