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    <title>2023 (4) TMI 314 - ITAT AHMEDABAD</title>
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    <description>The appeals contesting the disallowance of commission expenses by the Assessing Officer and upheld by the Commissioner of Income Tax were dismissed. The disallowance was based on the absence of documentary evidence proving services rendered by closely related persons to whom the commission was paid. The application of Section 40A(2)(b) was referenced, and the principle of consistency in allowing commission expenses was rejected. The disallowance was upheld for both assessees, and penalty proceedings under Section 271(1)(c) were deemed unjustified.</description>
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      <description>The appeals contesting the disallowance of commission expenses by the Assessing Officer and upheld by the Commissioner of Income Tax were dismissed. The disallowance was based on the absence of documentary evidence proving services rendered by closely related persons to whom the commission was paid. The application of Section 40A(2)(b) was referenced, and the principle of consistency in allowing commission expenses was rejected. The disallowance was upheld for both assessees, and penalty proceedings under Section 271(1)(c) were deemed unjustified.</description>
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