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    <title>2024 (7) TMI 775 - ITAT DELHI</title>
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    <description>Ad hoc disallowance of business expenses and bank interest was found unsustainable because no concrete adverse material showed defective books or diversion of borrowed funds, so the Revenue failed on those additions. Salary addition was also deleted since no salary was actually received and the TDS entry had been corrected by revised return. Deduction under section 80IC was allowed on the same business facts already accepted in earlier years, with no fresh material to support denial. For later years, selling and distribution expenses under section 37 were supported only in part, so the Tribunal reduced the estimated disallowance as the original percentage was excessive on the record.</description>
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      <description>Ad hoc disallowance of business expenses and bank interest was found unsustainable because no concrete adverse material showed defective books or diversion of borrowed funds, so the Revenue failed on those additions. Salary addition was also deleted since no salary was actually received and the TDS entry had been corrected by revised return. Deduction under section 80IC was allowed on the same business facts already accepted in earlier years, with no fresh material to support denial. For later years, selling and distribution expenses under section 37 were supported only in part, so the Tribunal reduced the estimated disallowance as the original percentage was excessive on the record.</description>
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