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    <title>2024 (10) TMI 1562 - ITAT MUMBAI</title>
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    <description>Disallowance of contingency expenses under section 37(1) was held unsustainable where the expenditure was already recorded in the regular books and the Revenue failed to show any defect or positive evidence of unrecorded outgo. The project cost reflected in the cost-to-completion reports matched the total expenditure in the books, even though the allocation under individual heads differed. Presumptions under section 132(4A) were held applicable to search cases and not to survey proceedings. In the absence of cogent material proving bogus booking or cash expenditure, suspicion, estimation, or alleged SOP non-compliance could not justify the addition, and the disallowance was directed to be deleted.</description>
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      <description>Disallowance of contingency expenses under section 37(1) was held unsustainable where the expenditure was already recorded in the regular books and the Revenue failed to show any defect or positive evidence of unrecorded outgo. The project cost reflected in the cost-to-completion reports matched the total expenditure in the books, even though the allocation under individual heads differed. Presumptions under section 132(4A) were held applicable to search cases and not to survey proceedings. In the absence of cogent material proving bogus booking or cash expenditure, suspicion, estimation, or alleged SOP non-compliance could not justify the addition, and the disallowance was directed to be deleted.</description>
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