https://www.taxtmi.com/caselaws?id=758094 The ITAT Delhi upheld the CIT(A)'s order dismissing Revenue's appeal on three grounds. First, regarding increased material costs, the Tribunal accepted the assessee's explanation that the 7% increase was due to higher INR/USD exchange rates (from Rs. 61 to Rs. 65.50 per USD) between AY 2015-16 and 2016-17. Second, for commission expense disallowance, the Tribunal rejected the AO's ad-hoc 33% disallowance based solely on commission increasing 73% versus revenue increasing 39.72%, finding no defect in the assessee's explanation. Third, regarding Section 40(a)(ia) disallowance, the Tribunal noted the AO incorrectly assumed payments to non-residents when they were to residents, and the assessee had already made 30% disallowance for non-deduction of tax. en-us Wed, 14 Feb 2024 00:00:00 +0530 Sat, 07 Sep 2024 08:18:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758094 The ITAT Delhi upheld the CIT(A)'s order dismissing Revenue's appeal on three grounds. First, regarding increased material costs, the Tribunal accepted the assessee's explanation that the 7% increase was due to higher INR/USD exchange rates (from Rs. 61 to Rs. 65.50 per USD) between AY 2015-16 and 2016-17. Second, for commission expense disallowance, the Tribunal rejected the AO's ad-hoc 33% disallowance based solely on commission increasing 73% versus revenue increasing 39.72%, finding no defect in the assessee's explanation. Third, regarding Section 40(a)(ia) disallowance, the Tribunal noted the AO incorrectly assumed payments to non-residents when they were to residents, and the assessee had already made 30% disallowance for non-deduction of tax. Case-Laws Income Tax Wed, 14 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758094